New York may seem a long way away but, make no mistake, if proposed legislation to ban the use of Carbon Black in printing inks is enacted, this lunatic cancel-culture movement could spread globally. Andy McCourt looks at recent reports from the US Print & Graphic Communications Association and Patrick Henry from Whattheythink.com.
All inks would be affected if the NYS bill passes into legislation (gratitude to creative nation)
Carbon Black is to printing and packaging what silicon is to silicon chips - without it industries dies and economies, even civilisations could collapse. Why? Consider this, when Gutenberg formulated his first ink he used 'Lamp Black' - the sooty fine powder that remains on glass after combustion. He mixed it with oils and other gummy substances and the formula was a closely guarded secret. Over 600 years later, those black impressions are still solid black and vibrant. The rag paper he used to print on has not been corroded by the ink mixture. People may have died in defense of what texts were printed, but no one in six centuries has ever died because of handling black ink.
Carbon 'Lamp' black is now produced on an industrial scale and is essential, not just for printing inks of all kinds (inluding inkjet and
toners), but in plastics, paints, textiles, car tyres - anything manufactured that needs to be black. As a fine powder, like any micro-particulate, it is hazardous if inhaled but bound up in various oils to make ink - soy, linseed, hydrocarbon, oil from nuts or trees even water with glycol or polymers - it is completely inert. Without carbon blackness, QR and Barcodes can fail, medical instructions can be corrupted and food-protecting packaging is compromised.
It may seem ironic but, as every printer knows, black is also essential in all other colours - especially CMY which, when colour managed, can produce almost every other colour. Black is the 'Key' colour in CMYK and every other special colour added to extend the gamut.
Alternatives to carbon black have been tried - and they don't work as well. Controlled burning of vegetation to collect soot and minerals such as iron oxide can all be found is some ink formulations but they either don't last, change to purplish-blues or rot the underlying paper or board material.
It can be easy to dismiss NY State's proposed legislation as too stupid to succeed but governments are capable of stupid policies on occassions - think Centrelink Robodebt or the UK Post Office's persecution of Postmasters when the accounting errors were all their fault due to faulty IT. Ignoring the issue would be like ignoring the first sneeze of Covid. The world can not afford to have this essential, harmless (when processed into inks) substance banned - just because it's got the word 'carbon' in its name. For goodness sake ALL lifeforms on this planet are carbon-based!
Following is the article from The Print & Graphic Communications Association of America's blog. Read and be astonished!
Andy McCourt
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NYS Considering Ban on Carbon Black – the Primary Pigment in Black Printing Ink
"Printing firms operating in New York State need to contact their NYS legislative representatives immediately (visit the PGCA Legislative Action Center to use our sample letter). Legislative bills S. 4246-B/A. 5322-B, newly amended and making their way through the NYS legislature, will enact several new environmental requirements for companies operating in New York State, if signed into law. While much of the proposed legislation is suspect, perhaps the most concerning element is a ban on the use of carbon black, the primary pigment in black printing ink. This legislation is aimed primarily at packaging and labels, but there are concerns that it is a “door opener” for a wider ban on additional products.
The introduction of NY S. 4246-B/A. 5322-B in February 2024, aimed at establishing an Extended Producer Responsibility (EPR) program and prohibiting the use of carbon black, among other things, has raised significant concerns within our industry. Banning carbon black from printing will create a profound negative impact on the printing and packaging industries, threatening thousands of well-paying jobs and affecting both the production and usage of printed materials.
The printing and packaging sector is a cornerstone of New York’s economy, encompassing approximately 260 businesses that collectively employ over 8,000 individuals and generate a payroll surpassing $400 million. The sector’s output, valued at nearly $2.8 billion annually, plays a pivotal role in the state’s economic landscape. The proposed blanket prohibition on carbon black jeopardizes not only thousands of jobs but also the entire economic activity surrounding this sector.
Moreover, the prohibition on carbon black would severely hamper the ability of manufacturers to print essential information directly onto packaging or labels. This restriction could lead to a significant communication breakdown, preventing critical information such as product identification, ingredients, usage instructions, warnings, manufacturer details, and expiration dates from reaching end-users effectively.
The bill cites toxicity concerns, interference with recycling processes, and issues of ink “bleeding” during recycling as the primary drivers for the proposed ban. However, it fails to recognize several important, science-based factors. Notably, when carbon black is incorporated into inks or used as a colorant for packaging, it does not exist in a form that poses the same health risks as the powdered form. This very critical distinction has been recognized by both the Occupational Safety & Health Administration (OSHA) and under California’s Proposition 65 program but is not recognized in NY S.4246-B/A.5322-B!
Additionally, technological advancements have significantly mitigated concerns related to recycling interference and ink “bleeding,” rendering the proposed ban both unnecessary and counterproductive.
There are additional concerns regarding the process for advancing this legislation.
- There has been limited opportunity for meaningful stakeholder input or discussion of the merits of this complex legislation. There is limited opportunity for stakeholders to provide public comments and for legislators to consider comments and evaluate the bill on its merits. The legislation imposes a wide ban on the presence of chemicals in packaging without clear environmental or public health justification.
- Additionally, there is no recognition of “de minimus” levels to account for substances that were not intentionally added, undermining the potential use of recycled content in products.
- Lastly, this bill also creates a Toxic Packaging Task Force that would recommend additional substances to be banned without a sound scientific basis, creating uncertainty for New York State businesses.
Legislation that rigidly adheres to the current technological landscape without accommodating the rapid pace of innovation risks becoming quickly outdated. It is imperative that the draft language of the bill be revisited to exempt printing inks and packaging materials containing carbon black from the ban. Such a revision would acknowledge the critical distinction regarding the form and use of carbon black, ensuring that legislation does not inadvertently compromise the viability and safety of packaging and printing inks. "
ENDS
Read the whole bulletin on THIS LINK
An additional well-researched article by Patrick Henry of Whattheythink.com can be read HERE
(Full acknowledgement to those who created and analysed information in the above 2 links)
