SGS, the world’s leading testing, inspection and certification company, is advising stakeholders that France will implement restrictions on two categories of mineral oil in ink for packaging and printed paper from January 1, 2023.
The French Ministry of Ecological Transition issued Decree of April 13, 2022, on May 3, 2022, regulating two categories of mineral oil. This follows Decree No. 2020-105 on the ‘Fight Against Waste and the Circular Economy’, published in 2020, Article 112 of which regulates mineral oils in packaging:
- January 1, 2022 – mineral oils prohibited from packaging
- January 1, 2025 – mineral oils prohibited from printing intended for the general public. (NB. January 1, 2023, for unsolicited advertising materials and catalogs for commercial promotions)
The law also allows the applicable conditions of Article 112 to be defined by Decree.
Articles D543-45-1 and D543-213 of the Environment Code and Decree No. 2020-1725 of December 29, 2020 ‘Various Adaption Provisions Relating to Extended Producer Responsibility’, set the conditions for the implementation of restrictions relating to mineral oils containing substances that disrupt the recycling of packaging wastepaper or restrict the use of recycled materials because of the risk of these substances to human health. Decree of April 13, 2022, implements the requirements in Articles D543-45-1 and D543-213 and Decree No. 2020-1725.
The Decree contains several important provisions:
- Pushes back the effective date for Article 112 of Decree No. 2020-105 from January 1, 2022, to January 1, 2023
- Defines mineral oils as oils produced from feedstocks derived from petroleum hydrocarbons used in the production of inks
- Provides a specific definition for mineral oils and specifies their requirements in ink:
- MOAH (mineral oil aromatic hydrocarbons) consisting of one to seven aromatic rings
- MOSH (mineral oil saturated hydrocarbons) consisting of 16 to 35 carbon atoms
- Indicates that compliance can be checked before or after application or printing (Section 3)
Stakeholders should be aware the restrictions on MOAH and MOSH do not apply to packaging, printing intended for the public, letters from advertising leaflets and unsolicited catalogs aimed at commercial promotions if there are specified requirements in a community provision that expressly authorizes the use of the (mineral) oil in the ink.
The effect date for the Decree is January 1, 2023, and there are two transitional periods:
- Packaging and printed matter of paper manufactured or imported before January 1, 2023, is required to be disposed of by December 31, 2023
- Compliant packaging and printed paper manufactured or imported before specific deadlines is required to be disposed of within 12 months of those deadlines
For more information on the requirements for MOSH and MOAH and the specific deadlines, read SGS’s original SafeGuardS 068/22.
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For further information contact:
Dr. HingWo Tsang
Global Information and Innovation Manager
Tel: (+852) 2774 7420
Pascale LAMBERT-DESMURS
Expert Global Contact Alimentaire et Chimie E&E
Tel: +33 6 85 93 63 00
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Website: www.sgs.com/cgnr
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