Avery Dennison prides itself on compliance, ensuring our company meets global regulations and helping our customers to quickly and easily do the same. Avery Dennison Digital Ink Solutions (DIS) is no exception. DIS offers high quality, reliable inks for a constantly broadening range of industries and applications. Partnering with OEMs and industrial ink customers, DIS looks for opportunities to customize and innovate the digital ink industry to meet every need.
Ink consumption, especially digital inkjet, is growing on the back of secular demand, the shift to digital printing, and moves to direct printing. However, this strong growth comes with a challenging regulatory environment. Chemical regulations are constantly changing and can vary widely among states, countries, and regions. In many places, chemical control laws are becoming increasingly stringent with an emphasis on the health and safety of humans and the environment. Chemical regulations, like TSCA and REACH/CLP, in the U.S. and EU respectively, can affect the manufacture, transport, import, and use of chemical products.
Chemical data, Globally Harmonized System of Classification and Labelling of Chemicals (GHS) adoption, GHS building blocks, cut-offs, concentration limits, and more can affect a product's classification and may result in different classifications around the world. For example, if a chemical is classified as a Reproductive Toxicity Category 1A and is in a final product at a concentration of 0.2% (w/w), in the U.S., the finished good would be classified as Reproductive Toxicity Category 1A, as well, because the cut-off/concentration limit for this endpoint is 0.1%. In contrast, the cut-off/concentration limit in the EU is 0.3% for Reproductive Toxicity Category 1A, so this component would not contribute to a reproductive hazard classification for the product. In addition to variations in GHS classification, marketplace acceptance between countries may vary if, for example, a component of a product is considered to be a Substance of Very High Concern (SVHC) under EU REACH, but is not considered especially hazardous elsewhere. From lists of chemicals like SVHCs and chemicals subject to Authorization in the EU to Proposition 65 in California, there are many different factors in each region that affect how the safety of a product is viewed.
Over the past few years, significant changes have been made to global regulations resulting in prioritization and risk assessments of existing chemicals, increasing restrictions on chemicals in commerce, and a more robust review process for new chemicals. These changes have forced manufacturers to take a risk management approach to the products they place in the marketplace and progressively substitute hazardous chemicals with safer alternatives to better protect human health and the environment. There is also a strong global focus on gathering data on new and existing chemicals and reducing the amount of confidential business information that is acceptable from manufacturers to promote transparency and better understand the risks of chemicals in the marketplace.
Beyond governmental regulations, there are often company-specific requirements and industry standards that need to be considered in overall product compliance. Avery Dennison has a “Restricted Substance List” (RSL) that follows our product standards which is referenced along with applicable customer RSLs when designing new products. Also, depending on the intended use of the ink, there can be additional regulations to follow. For example, if the intention is to use ink for printing on a food package, there are specific food contact regulations that must be met, which differ greatly by region. As a global company, it is important for us to be aware of chemical regulations worldwide to enable manufacturing, sales, transport, and customer safety and satisfaction in any region. To facilitate compliance, Avery Dennison makes it a priority from the beginning of a product’s life cycle. At the early stages of R&D, we assess a product’s ability to be manufactured in our U.S. facilities, sold into desired market segments, meet customer and marketplace expectations, and be safe for our downstream users and the environment.
The safety of downstream users is the most important reason for product compliance - accurate labels and SDSs are vital in the communication of how to safely handle a product. In addition to criteria for classifying physical, health, and environmental hazards for chemicals and mixtures, GHS provides guidance on hazard communication, including the information that must appear on labels and safety data sheets (SDSs). Though the goal of GHS is global harmonization, SDS and label requirements vary worldwide, so the proper documents must be in place for every intended market segment. Without proper hazard communication, sale of products worldwide can be hindered or even stopped.
Safety and communication internally is also a priority at Avery Dennison. In December 2019, the Reflectives and Digital Ink Solutions plant in Painesville, Ohio, where digital inks are manufactured, recorded more than 2,000 days free from Recordable or Lost Time Accidents. As this number continues to grow, the plant still continues to find ways to improve on the safety of the plant and their employees.
Customers often have questions about our inks that they need answered in order to keep their employees safe or meet their own compliance needs or their customer’s. Using our experience and expertise, we aim to answer these questions quickly and efficiently and provide the information our customers need to be successful. As our business continues to broaden and we enter more market segments, and as global regulatory compliance continues to change, DIS will continue to learn, innovate, and provide compliant, high-quality inks that meet our customers’ needs and transform the digital printing industry.
Learn more about Avery Dennison Digital Ink Solutions here.
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