Preparing for 2026: Understanding the Impact of the German Ink Regulation

On December 7, 2021, the German Printing Ink Ordinance (GIO) was officially published (BGBl. I 2021 p. 5068, No. 82), establishing a new and stringent benchmark for food contact materials. Set to come into full effect on January 1, 2026, after a four-year transitional period, the GIO introduces one of the most demanding regulatory frameworks globally raising the bar for manufacturers of printed food contact materials.

While the ordinance has been met with criticism from industry stakeholders and concerns from the European Commission about its unilateral nature, it has nonetheless been adopted as national law in Germany. The GIO aims to safeguard consumer health by setting high standards for materials that may come into contact with food, both directly and indirectly.

What the GIO Covers and Why It Matters

Despite its name, the GIO does not regulate printing inks in isolation. Instead, it targets printed food contact materials where substance migration from the ink layer to food cannot be ruled out. The ordinance applies to both:

• Direct contact scenarios (where the ink faces the food), and
• Indirect contact scenarios (where ink is printed on the non-contact side but could still pose a migration risk).

At its core is a positive list of permitted substances (Annex 14, Tables 1 & 2), limiting the formulation of inks to pre-approved components. The GIO also references the EU Regulation No. 10/2011 for plastic food contact materials but only includes substances without specific restrictions. This narrower scope makes compliance even more complex compared to existing regulations such as the Swiss Ordinance.

While the possibility exists to add additional substances to Annex 14 during the transitional period, the process is expected to be rigorous and unpredictable.

How the Industry is Responding

For the vast majority of inks used in indirect food contact, the path to compliance is already underway. The printing ink industry is pursuing three parallel strategies:

1. Collaborating with raw material suppliers to register and add missing substances to the positive list.
2. Reformulating products to rely exclusively on already listed substances.
3. Using non-listed substances cautiously, provided they are non-CMR (non-carcinogenic, mutagenic, or reprotoxic) and migration remains below the threshold of 10 ppb.

DF Inks’ Proactive Compliance Strategy

We view regulatory compliance not as a burden but as an opportunity to raise the bar on product safety and performance. Our commitment includes:

• Careful raw material selection
• Continuous production monitoring
• Specialized migration testing and toxicological assessments

This approach ensures our products are not only compliant with the GIO but also aligned with evolving customer expectations and the most advanced regulatory standards worldwide.

As a responsible industry leader, DF Inks is prepared for the GIO and positioned to support its partners in navigating this complex regulatory shift. By investing early in innovation and compliance, we continue to reinforce customer trust, while advancing safe, sustainable packaging solutions.