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Labelling regulations

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Labelling regulations

  1. 1. Packaging information regulations: How they can affect the graphics and printing industry.
  2. 2. Packaging helps to preserve and protect, ensuring that a product reaches its final destination in good safe condition. But what if people have allergies to the ingredients, or maybe the ingredients carry other health risks? Some people can develop reactions to seafood, peanuts, eggs, milk, cereals, and consuming even a tiny amount of the product can cause life-threatening reactions. Such allergies appear to be more and more prevalent, which could mean that humans are becoming more sensitive to particular foods, or it could mean that we now understand such conditions better from a medical viewpoint. European regulations (Food Information Regulation, or FIR) have come into effect to ensure that all food packaging highlights the ingredients known to cause reactions in people. On December 13th 2014 the EU declared that “For pre-packed foods, allergen information must be emphasised in the ingredients list”. In 2016 mandatory nutritional declarations will also be required, listing the fat and sugar content (for instance) which can be important when selecting a product. In the UK most of the food industry decided to voluntarily conform to this 2016 regulation now. Such legislative changes can put a strain on the printing industry because the normal production can be severely disrupted. Firstly when the legislation is being developed, there is uncertainty around what will be required to change, and when. Consumer Products Companies wait to see what the new legislation will bring, and packaging development stops.
  3. 3. When the legislation is finalized, there is a rush to meet the deadline and so a rush to change graphics, create colour standards, meet demand whilst phasing out the old design, and so all departments in prepress and printing environments are put through immense strain. Then there is a natural slowdown after the event, as new designs are not seen for quite some time. When Canada went through its own food/nutrition declaration legislation in 2005 the industry (especially prepress) saw a 25% increase in turnover that year, the following year, there was a sharp decrease in activity. This week the UK Department of Health decided that the packaging of tobacco packaging will be ‘standardised’, following the example of Australia where cigarettes are sold in brown packaging with the company name, product name in simple text, and health warnings being the only graphic elements. The idea that is held by many is that the current stylized packaging of tobacco products makes them look ‘glamorous’, and that this attracts new customers to smoking. Governments typically try to discourage smoking without banning it completely. For the past few years tobacco companies, anticipating these restrictions, have been competing for market share by changing designs often and adding new features such as holograms. The thought has been that once ‘plain’ packaging comes into effect it will be more difficult to move customers from one brand to another. Litho and gravure printing presses dedicated to this work often have 10 or more print stations so that all of the special colours and effects can be printed, alongside four colour
  4. 4. health warnings. Off-line effects and special laminates are often used. This area of print has, in my opinion, seen more advancement and innovation in the visual appearance of the product than any other. As the tobacco companies have looked for new and interesting ways to differentiate their packaging, they have worked with printers to develop new effects. It is thought that smokers may ‘dwell’ on the product for longer, find it interesting, perceive the quality of the product, and are therefore more likely to buy the product. The future for tobacco packaging printers is going to be ‘interesting’. Their markets have opened up to include eastern European countries, Asia is always expanding, and Africa is a continent that has not yet been served by many larger companies. However that is contrasted by legislation that limits their activities (in Australia and UK) with no doubt more to follow, and so some of the large multi-station printing presses many not now be so important. I predict that their focus will be widened to include other areas of primarily boxboard packaging and so confectionary (eg. High end chocolate) and high value goods such as cell phones will benefit from many of the innovative techniques developed for tobacco packaging. About 12 years ago the Canadian government legislated that colour health warnings would be added to tobacco packaging. At that time the designs used perhaps 6 or seven special colours or effects, printed onto 8 colour presses. As the colour health warnings used CMYK, suddenly the brand graphics needed to be produced much more simply out of process, or a reduced number of special colours.
  5. 5. The legislation was challenged in the courts but the legislation went ahead. The industry woke up, with about 6 months before the deadline, and realized that every design would need to be changed in a very short period of time. As the tobacco packaging was produced using gravure, every gravure cylinder would need to be re-engraved. Not only that, but additional health warnings meant that more cylinders were needed. The logistics involved were incredible. More cylinders need to be manufactured, graphics need to be created, tests run, and cylinders engraved. Printers needs to sort inventory, manage the logistics, develop new inks, run tests, approve graphics, and then meet their delivery commitments. It was to say the least chaotic. What it did to the prepress industry was firstly create a slowdown, then maximum production capacity was required (with the addition of staff and shifts) for 6 months, and then another slowdown followed. For printers it was an event that caused production and quality problems. Previously CMYK had not been used much for tobacco products. The need for CMYK images was a challenge as presses needed to be colour profiled and fingerprinted, and it was not an elegant process given the time constraints. Anyone with knowledge of lean manufacturing will know that it is very difficult to gear up for ‘events’ such as this. When the Canadian government decided to increase the size of the health warnings on packs (from 50% to 75%) in 2008 they consulted with the industry. The sessions held were mostly directed at educating the govt representatives in printing techniques, in an attempt to simplify the demands of the new legislation on the industry.
  6. 6. This time around more planning went into the overall process of design, and complex critical paths were created. This ensured that designs were aligned so that the ones that were created first, were engraved first and then printed first. This meant that the production flow was kept more constant, with less extreme ‘peaks and valleys’. This time around the whole industry was much more adept at printing CMYK and colour profiling techniques had advanced to provide the tools needed to accurately predict the final results. The difficulty for companies involved is that one year they can see their New Product Development and Life Cycle Management activity increase dramatically one year, and fall the next. Staffing and resourcing is very difficult, and it is difficult on the companies, employees and families who find themselves affected by these short term events. The recent European FIR regulations placed a huge demand on the food packaging industry. Firstly consumer product companies needed to review all ingredients used and decide if specific allergens were necessary. Then they needed to analyse and verify all products so that the correct nutritional information was obtained. This was then used on new packaging. As all package graphics needed to change, many brands were refreshed at the same time. This ‘brought forward’ much work that would normally have been undertaken in the following years. Some designs previously only required a few colours. Therefore the designs would have used perhaps four or five spot colours. The new legislation means a ‘traffic light’ system is used to convey food content such as fat and sugar,
  7. 7. with ‘Green’ meaning Low (eg. Low Fat, Low Sugar) Amber meaning Medium, and Red meaning High. Additional print colours were needed, in some cases more colours than a printing press will allow. Colour separation techniques such as Extended Gamut were used in many cases. This is when CMYK plus Red, Green and Blue (for instance) are used on press and tints of each used to make up any other colours required. Such ‘events’ due to legislation changes challenge a production plant’s ability to manage the process. A sign of a weak system is when, during these times of maximum production, the process not followed because ‘there isn’t enough time’. Work is processes ‘rush’, QC checks are skipped, people unfamiliar with the process are used and mistakes are made, then complaints and claims follow. A sign of a strong system is when production works in the same way, perhaps for longer hours. Additional equipment may be implemented, but essentially it is the same process. Reaching this state is normally only achieved by adopting Lean Manufacturing techniques (plus the many tools such as Six Sigma, Just In Time, Continuous Improvement, ISO9001 etc). It is often difficult to challenge a process when everything appears to work fine. However a system is not necessarily robust if it works well when at average production throughput. Continuous improvement and the development of new techniques whose success can be measured in time saved, costs saved, improved products, must be an ongoing process. Companies that become complacent can struggle through the ‘peaks’ that our industry sees, resulting in lost opportunity, and lost customer confidence. Companies who
  8. 8. continually strive for excellence become more effective and efficient, make more money, and can use busy times to underpin their businesses and make more money. Further regulatory changes are coming, to every region of the globe, it is just a matter of time. Health concerns, green concerns, concerns over the effects of products on people, will always be there and develop based on new information and political pressure. Packaging is the best, and ultimate, communicator, and so it is inevitable that we will see far more legislation affecting our industry in time.

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