A draft amendment to the German Printing Inks Ordinance/Consumer Goods Ordinance (in German) was submitted to the German Bundesrat (the Federal Council of Germany) in November 2025 and is likely to be adopted shortly. 

As background, Germany adopted the 21st Amendment to the Consumer Goods Ordinance (aka the Printing Inks Ordinance) in November 2021. It applies to both printing inks and varnishes intended to come into contact with food (direct and non-direct food-contact) and includes a positive list of allowed monomers, additives, colorants, solvents, and photoinitiators. The transition period for the applicability of the positive lists in the Printing Inks Ordinance was four or five years (until the end of 2025 and 2026), depending on the provisions. This was to allow industry time to submit petitions for printing ink components.

The new draft text proposes to delay the application of the positive list in Annex 14, Table 1, Appendix 14 of the Printing Inks Ordinance from December 31, 2025, until December 31, 2026. It also proposes updates to the positive list, along with several other amendments to the Consumer Goods Ordinance that take into consideration newer legislation at the EU level and update penalty provisions for breaches of the food contact legislation. 

It is expected that the Committee on Agricultural Policy and Consumer Protection of the Bundesrat will vote on the new draft amendment on December 1, 2025, at its 916th meeting. Thereafter, the draft text will go to the Bundestag for final approval and promulgation. 

In a separate but related matter, the German Institute for Risk Assessment (BfR) published a Guideline for the safety assessment of substances for inclusion in Appendix 14 Table 1 of the Printing Inks Ordinance. The Guideline is intended to assist industry with the petitioning process for printing ink components.