Jay Betton

UPM Raflatac

Business Segment Manager

(FSB)

Food, Retail & Logistics

UPM RAFLATAC

| © UPM

UPM today

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• Global operator - Sales operations in 67 countries, production in 17 countries

• Sales 10,4 billion euros in 2012

• 22,000 employees

• Listed in the NASDAQ OMX Helsinki stock exchange

UPM

Biorefining

UPM

Energy

UPM

Raflatac

UPM

Paper Asia

UPM

Paper ENA

UPM

Plywood

• Biofuels

• Pulp

• Plantation operations

• Timber

• Wood sourcing

• Hydro, nuclear and condensing power (incl. shareholdings in energy companies)

• Physical and derivatives trading

• Self-adhesive label materials for product and information labeling

• Fine papers in China

• Label paper business

• Magazine papers Europe and NA

• Newsprint and fine papers Europe

• RCP and wood sourcing

• Plywood and veneer products

Other operations: Forests (over 850,000 hectares) and wood sourcing, New Business Development and Group

services

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UPM Raflatac

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* Excluding special items

Key figures 2012

Sales (M€) 1,202

Operating profit (M€)* 81

Personnel 2,873

Self-adhesive label materials for

product and information labelling

• Production in 13 factories:

Tampere/Finland, Scarborough/UK,

Nancy/France, Polinya/Spain,

Kobierzyce/Poland, Nowa Wies

Wroclawska /Poland, Dixon/USA,

Fletcher/USA, Mills River/USA, Rio de

Janeiro/Brazil, Changshu/China,

Johor/Malaysia, Melbourne/Australia

• Slitting and distribution terminals

and sales offices worldwide

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Self-adhesive labelstock

Matrix

Release coating Adhesive

Release liner

Face material

Self-adhesive label

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Label materials for a wide variety of

product and information labelling

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Tyre

Wine

Security &

Brand protection

Logistics &

Transport

Oil &

Industrial

Chemical

Beverage

Food

Home care

Personal care

Pharmaceuticals

Retail

A4 &

Cut-size

Durables

EC1935/2004

EU10/2011

Food Safety

Food Contact Materials

(FCM)

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Original legislation somewhat ignored the role

of the label in packaging

• The main legislation in Europe for food

contact materials is frame regulation

EC 1935/2004

• It applies to ALL food contact materials

and the functional barriers

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Existing legislation has been updated to

‘better’ account for labels

• There are specific measures (detailed

requirements) for different types of Food

Contact Materials (FCM)

– Active and intelligent materials and

articles, Ceramics, Regenerated

cellulose and

– Plastics EU10/2011

• Resolution already for papers and silicones

Internal 8 Legislation document

http://ec.europa.eu/food/food/chemicalsafety/foodcontact/legisl_list_en.htm

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When we drill down into ‘plastics’ in

Regulation EU 10/2011

It applies to:

a. materials and articles and parts thereof consisting exclusively of

plastics;

b. plastic multi-layer materials and articles held together by

adhesives or by other means;

c. materials and articles referred to in points a) or b) that are printed

and/or covered by a coating;

d. plastic layers or plastic coatings, forming gaskets in caps and closures,

that together with those caps and closures compose a set of two or

more layers of different types of materials;

e. plastic layers in multi-layer materials and articles.

• So not directly for adhesives, adopted nonetheless.

Internal 9

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Food contact under the original legislation has

changed…

Direct food contact approvals were

needed when

- the material was actually in contact

with the food

- i.e. fruit labelling, meat labelling

Indirect food contact approvals were

needed for

- the layer in contact with the

package, not necessarily for the

face material (in the case of labels)

Internal 10

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…new tighter rules are in place

Compliance to legislation and a

declaration needed when :

- The material has direct contact

with the food

- i.e. fruit labelling, meat labelling

Compliance to legislation and a

declaration needed with :

Indirect food contact, if there is the

possibility for the substances to

transfer into the food, i.e. primary

indirect labelling

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Where it is not needed is Secondary

Indirect labelling where there is no

possibility of contamination

Internal 12

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Each stage of the packaging chain is

responsible for their own conformance and

declarations

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CHEMICAL

SUPPLIER

•Declaration

regarding

chemicals…

•Adequate

information

regarding

chemicals

• Information of

applicable

legislation

• Information on

restricted

components

• Information of

dual use

substances

PACKAGE

AND LABEL

MANUFACTURER

•Adequate

information

regarding

packaging

materials (film,

paper, label)

• Information of

applicable

legislation,

restricted

components,

overall migration,

organoleptic

properties.

PRINTING

HOUSE

•Adequate

information

regarding printed

packaging

materials

• Information of

applicable

legislation,

restricted

components,

overall migration,

organoleptic

properties.

FOOD

PACKAGING

COMPANY

•Final

responsibility on

compliance

•Based on

declarations of

compliances

through the chain

and/or migration

testing with final

packaging

material.

PRODUCT

CONSUMPTION

•Safe usage of

labelled products

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The contents of a Declaration of Conformity

• Name and address of the supplier

• Identification of the product

• The date of the declaration

• Statement of the compliance e.g. EU, national legislation, BfR, FDA…

• Information of components subject to specific restrictions e.g. Specific Migration Limits (SML)

• Dual-use additives (identity)

• Information of surface active biocides used (for adhesives only)

• Specifications on the use of the material – type of food, time and temperature in storage i.e. migration results (ISEGA)

– Overall migration (typically films)

UPM Raflatac documentation is based on written

declarations from suppliers.

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DoC Availability from UPM Raflatac

• Main grades used in Food Labelling

• (Paper face materials)

• Filmic faces

• Adhesives

• (Some backings) (+silicone)

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Consumer Safety is Paramount

• Many existing labels may already have food approval

– Simply need DoCs to prove this

– Main adhesive lines already have this at no extra cost

• Risk of supply of non-compliant labels…

• Non-compliant materials risk migration of unsafe contamination…

• Contamination increases concerns for consumer safety…

• Consumer safety concerns could result in product recall…

• Product recall results in

– Potentially large consequential costs…

– Significant damage to brand value

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