California Prop 65 UV Coatings

Prop 65
Why Prop 65?

In California, Prop 65 requires the state to publish a list of chemicals known to cause cancer, birth defects or reproductive harm. The law requires a warning label on anything containing these. Benzophenone was listed in 2012. Benzophenone (BP) or Benzo, has been generally recognized as the most used Photoinitiator (PI) globally. It is known for its effectiveness as an initiator, and its relative low cost. UV printing ink and coating manufacturers have responded by replacing low molecular weight, high migration potential PIs. As a result, benzophenone & ITX free formulations have been made available, notably for food packaging. In other moves, raw material suppliers continue to develop self-curing resin solutions, new large molecule, low migration, low odor polymeric photoinitiators (PPIs), and co initiators. Significantly, these changes have become price drivers for UV curing products.


Photoinitiators are a key component and a cost driver for UV curing products. They are capable, as their name implies, of initiating or starting a photoreaction. This occurs when a PI absorbs radiation energy from light exposure to produce highly reactive free radicals and ionic species. These have the capability of catalyzing or starting chemical reactions, or changes in certain formulated materials. One such photoinitiator is Benzophenone.

Health Concerns

In the last several years, a health concern has developed, especially in Europe, regarding the migration of small molecule PIs, into foods from indirect food contact packaging materials. It is thought that a PI like methyl benzophenone (MPB) can reach packaged food in two ways, (1) an indirect transfer from the vapor phase of semi-volatile PIs, (2) from direct contact stemming from permeation or set-off when cured printing inks and coatings come in contact with the inside of a package surface as packaging material is stacked or processed in roll form. When migration into food has been found, the packaged food and the packaging materials used have been removed from use.

The European Printing Ink Association (EuPIA) has published a listing of PIs used in coatings, inks and varnishes for the non-contact side of food packaging. These are listed as Group 1-For all packaging types. 1A-low migration potential with toxicological data. 1B-low migration potential and/or high molecular weight, awaiting evaluation. 1C-evaluated with a migration limit in accordance with EU RG. No. 10/2011, and/or Swiss Ord. 817.023.21. The 1C list includes Benzophen-one and derivatives. Group 2-lists PIs not fully evaluated specifying use only with a metal barrier. This has resulted in packaging specifiers requesting that certain PIs with migration potential not be used on their (in-direct contact) food packaging products.

Cork Industries offers benzophenone free UV coatings for packaging and print protection.  Please contact our customer service line at (610) 522-9550 to speak with a UV Coating Expert.

More information on California’s Prop 65 is here from




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Elmer W. Griese Jr.

Technical Writer & Educator

Elmer W. Griese Jr, having accumulated 35+ years of knowledge working in the coatings and printing ink industries has now authored the Cork Tech Talk News, newsletter since 1992 producing 112 issues. He remains dedicated to educating and illuminating technological progress that offers the potential to advance coating technology and its applications.

Elmer W. Griese Jr.

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