Market Focus

Food Labeling

March 6, 2009

Issues abound in this complex segment of the packaging industry.

Food Labeling

Issues abound in this complex segment of the packaging industry.

By Steve Katz

Food labels are versatile. In general, they are designed to complete two distinct tasks: market the product and inform the consumer of the facts associated with the food item itself. They also must comply with rules and regulations. But if only it was this simple. In a discussion about food labeling, the conversation covers many topics, and pretty much everyone is involved – suppliers, converters, end users and consumers all play key roles.

On the marketing side, enticing the consumer to purchase a particular food product over its competitors, those that share the same shelf space, is the name of the game. To this end, marketing professionals create branding and promotional strategies. Like consumer’s tastes, strategies change, and in recent years shoppers have been inundated with wording and phrasing designed to appeal to their sensibilities pertaining to health and wellness. Walk down the various food aisles of any grocery store and chances are you’ll come across words and phrasing such as “organic,” “all natural,” and “reduced fat,” to name a few.

In addition to catering to the diet and nutritional fads of the day, food labels are required to adhere to the labeling laws set forth by governmental agencies such as the US Food and Drug Administration (FDA) and the US Department of Agriculture (USDA). These are not just guidelines, but laws. The USDA specifies in great detail information required on labels that pertain to dating, ingredients and additives, and specific wording. For example, to avoid ambiguity, the USDA spells out the exact requirements that must be met in order for its label to claim that the product is “fresh.”

While marketing departments are following the legal guidelines in regard to the verbiage used on food labels, they’re also working to sell the product with graphics, combining words and pictures designed to entice the consumer. Adding to the mix is another set of regulations regarding direct and indirect contact between label materials – inks, adhesives and substrates – and the food product itself, thus making food labels a complicated segment of the converting industry.


The formula for determining the effectiveness of a food label is rather simple. The label does its job if the product is purchased over the competition. For many consumers, particularly shoppers without an agenda, list, or specific product in mind, the window of opportunity for the food product to relay its message is relatively short.

Peter Schambs, product and sales manager for Digitalabel, an all digital label printer based in Durham, NC, USA, says, “A legible, eye catching and appealing label is what all printers and end users hope for. The customer gets that one- to two-second glance on the shelf from potential buyers of their product, and if the label is not successful, there is no sale.”

Joel Carmany, president of Consolidated Label, Longwood, FL, USA, talks about the multiple jobs an effective food label takes on. “The first job the label has is to impress the consumer enough so that he or she selects the product from the shelf, as opposed to its competitors. Second, the label has to inform consumers about product directions and ingredients,” Carmany says, pointing out that a food label is often part of a much bigger picture. “The label has to help create the vision for the brand, and in many cases, be cohesive with a family of products offered by that particular brand,” he says.

Carmany discusses what he feels makes for an effective food label, as well as the significant role that branding plays in a label’s makeup. “An effective food label usually has, in most cases, a four-color process picture of the product – usually cooked and ready to serve. This is so the consumer can imagine how great this product will taste. Also, the label will feature some form of signature wording such as ‘good to the last drop,’ or ‘you can’t just eat one.’ These statements help in brand creation. It will always carry the brand logo which will be prominent at the top of the label.”

As far as the current trends of the day, Carmany says food labels are appealing to the consumer’s desire for improved health and longevity. “The major trend in food labeling today is putting a focus on the ‘healthy’ and ‘natural’ aspect of products. Consumers are interested in living longer and healthier lives and brands are playing into this. With that in mind, labels for food products are carrying statements such as ‘fat-free’ or ‘will lower your cholesterol,’ for example,” Carmany says.

While marketing campaigns and catchy slogans are a major part of a food label’s graphic content, it should also be pointed out the symbiotic relationship that exists when promotional labels are used in conjunction with a food label. Promotional labeling is another market segment that features a variety of different concepts that are a natural fit for food products. Expanded content labels, for example, provide an opportunity to offer recipes, cooking instructions, or tell the the manufacturer’s story. Money saving coupons and sweepstakes are also valuable tools food products use to generate shelf appeal and differentiate from competitors.

Frank Connelly, president of Western Shield Label Company, Rancho Dominguez, CA, USA, talks about situations in which converted products that are classified as being promotional can provide a boost to food labels. “Coupons are effective tools for increasing sales dollars for pennies, particularly in difficult economic times. We have also seen an increase in expanded content for food labels, which offer recipes, secondary languages, directions for use, or space for other labeling needs or regulations,” he says.

Cheryl Caudill, corporate communications manager for Multi-Plastics, Lewis Center, OH, USA, supports the aforementioned trends with her observations. She says, “Markets with high growth include organic, health, age and ethnic foods. In addition, during times of economic uncertainty, private label brands tend to make a comeback when consumers are making a conscious effort to try and save money.”


Joel Carmany points out that many food labels used to be glue applied paper labels, and a lot of these applications have moved to pressure sensitive over the last three decades. Specifically, he says, in recent years there’s been a move to foil and clear labels, targeting the higher end markets. “Kraft recently moved to clear labels for their salad dressing line. Changing a product’s look is a constant, ongoing theme to keep brands fresh and looking new on the shelf,” he says.

Kraft and Tostitos have both recently moved to no-look labels.
Laura Clark, marketing director for food and beverage, Avery Dennison, Pasadena, CA, USA, also notices brands moving toward clear labels. “In the pressure sensitive market, the no-label look is gaining in popularity in both the food and beverage industry. We are seeing strong growth in dressing and condiments, dips and salsa, water, juice and tea categories. Clear labels with high quality graphics are a low cost vehicle for consumer product goods companies to differentiate themselves at retail, create shelf impact and convey consumer benefits of freshness and quality while reinforcing their brand message and position,” she says.

Multi-Color Corporation, Cincinnati, OH, USA, manufacturers a wide variety of different types of food labels. Dirk Edwards, marketing manager, says that no matter the type of label made, it’s effectiveness relies on how well it gets its message across. “MCC sells food labels across all five application technologies – in-mold, pressure sensitive, heat transfer, cut-and-stack, and shrink sleeve. No-label looks with in-mold and heat transfer continue to gain ground in this market segment as manufacturers evaluate package redesign efforts. Market trends in this area include a desire for simplicity, staying at home, and products that meet a specific purpose. However, regardless of application technology, the label must complement the overall package and communicate the market position of the product effectively to the desired target demographic. Also, I think that the market segment will continue to grow with manufacturers seeking out ways to differentiate their product offerings through package redesign efforts as time and resources permit,” he says.

Robert Petrie, VP of wholesale markets for Century Marketing, Bowling Green, WI, USA, a company that has a converting branch called Century Label, says that digital printing for food labels is on the rise. “There has been an explosion in digital food label printing. In addition to the excellent quality of digital printing, digital affords opportunities for multiple copies, affordable shorter runs, and fast turnarounds. Also, digital diecutting can be done with no tool cost, allowing customers to receive affordable prototypes that they can use for FDA and corporate approval,” he says.

Cheryl Caudill of Multi-Plastics points out reasons that some brand owners have moved from using standard PS labels to other forms of packaging. “Food labeling has always included a need for strong shelf appeal. Differentiation has caused products that traditionally used pressure sensitive labels to change over to a shrink label or flexible packaging. In addition to shelf appeal, some flexible packaging offers extended shelf life.”

Petrie also sees growth in shrink sleeve usage for food packaging. “Shrink sleeve printing has had great success in the food labeling industry. Shrink sleeves fit the contours of unique shapes, create a 360 degree graphic impact, and are digitally imprinted for a great quality look. Our digital shrink printing has grown in recent years.”

In addition, Petrie notices food labels that are utilizing a variety of special effects as a means to differentiate. “Another trend we’ve seen in food labeling is the use of metallic and holographic materials for a shinier, more eye-catching look,” he says.

Peter Schambs of Digitalabel also extols the virtues of digital printing when it comes to food label production, and points out a few niche examples. “With digital printing, each label can be radically different from the next. Since there are no printing plates required, digital printers are not limited by this additional cost and manufacturing restriction. We are also seeing food customers wanting to use a series of signatures on their items – implying that the president of their company or owner is proud enough to sign each product using multiple differing signatures,” he says.

Schambs notes that turnaround time is an additional advantage to digitally printed food labels. He says, “A huge plus is speed to market. Digitally printed labels are able to be manufactured in hours or days, compared to weeks with other printing processes.”

Schambs also points out challenges Digitalabel has been faced with and how the company’s speed-to-print capabilities help in overcoming them. “With all the changes imposed or requested by the FDA, or with something like food allergies, we have had to rapidly go to press to print add-on labels to customers’ existing hot sauces, BBQ preparations and sandwich spreads. These labels tend to be unobtrusive, yet convey the font and text required to impart the content or warning. Their size is usually restricted by the proximity available to add to existing labeled products. The challenge is how to squeeze information into a tight label. Digital printing is especially adept at this with exceptionally sharp clarity,” he says.

Communication, safety, contact, and the FDA

Communication among suppliers of label materials, converters, and end users is generally of critical importance, regardless of the market. Yet when it comes to supplies for food labels, this relationship is magnified. All players involved in the workflow, from concept to completion, need to be aware of FDA requirements and regulations. They should also be knowledgeable of the organization’s approved list of products classified as GRAS (Generally Regarded as Safe). The information is available on the FDA website,, but reading it and understanding it is a challenging process, yet certainly one that should never be taken lightly. The last thing anyone involved in food manufacturing wants to see is a headline-making recall of a food product due to an illness outbreak.

Contact and migration issues are of the utmost importance when converting food labels. (Photo courtesy of CRI)
After recent well-published outbreaks of E. coli and salmonella poisoning, the public has a heightened concern for food safety. “A good part of our job as an ink supplier has been to educate the narrow web printer on the regulations and on what we need to do together to be in compliance. Specifications are frequently vague and need clarification. The narrow web printers are very capable business people and have always known how to partner with the ink and substrate partners to do the right thing for their customers,” says George Sickinger, president and CEO of Color Resolutions International, Fairfield, OH, USA. “Our Product Development Lab spends about 60 percent of its time developing products for the label industry. CRI has developed three main ink systems designed for food product labeling – Label Choice Ink System, Profector Plus and Label Choice WR – and deciding on which one to use is determined by the specific application at hand.”

In order to procure the proper supplies, it is of paramount importance for end users to communicate with label converters in detail just how the label is going to be used.

Multi-Plastics’ Cheryl Caudill comments on the critical role a supplier plays in ensuring compliance. “In addition to the traditional requests for documentation (from government agencies), as a supplier, we have been asked to provide letters regarding BPA, melamine, allergens, nanotechnology, and phthalates because of public awareness of recent incidents that have made news headlines,” she says.

Caudill points to crosschecking with the FDA’s Code of Federal Regulation (CFR) Title 21 as an essential resource for making sure the material and its coatings are acceptable for the application. She also says that Multi-Plastics takes additional steps. “As a supplier of food contact films, we have taken further measures and have been audited by AIB International (formerly American Institute of Baking), which is committed to protecting the safety of the food supply chain and delivering high value technical and educational programs. Meeting their standards as a Food-Contact Packaging Manufacturing facility shows our commitment to the overall product safety of our customers who manufacture food contact products to be used in flexible packaging, carton or label applications.”

Mike Buystedt, general manager, Midwest, Flint Group Narrow Web, Plymouth, MN, USA, also emphasizes the importance of knowing exactly the intended application when supplying ink. “In all cases, the ink supplier needs to understand the application and the performance requirements that the ink needs to meet to recommend the correct product. When ink comes into direct contact with food it is considered an additive, and in this case you need to use an ink formulated with raw materials that are on the GRAS list and/or the FDA’s list of approved substances for direct food additive purposes.”

If the ink is being used on a label that’s going on the outside of a food package, Buystedt says there are no special requirements. “But,” he adds, “if a label is coming into contact with food, like a coupon for example, than the regulations for direct food contact apply. In flexo, water based is the most popular ink technology for food labeling applications, but both water based and UV inks are used for food labeling applications.”

CRI’s George Sickinger says that there’s significant misunderstanding in the industry regarding the terms “direct” and “indirect” contact as they relate to food packaging. “In food packaging, inks can be in either direct contact with a food product (i.e., a coupon inside a box of cereal) or in indirect contact with food, such as a label on refrigerated hamburger. In the latter indirect situation, the label is on the food package, but the ink itself is on only one side of the label. Hence, the label itself in combination with the package may serve as a functional barrier between the ink and the food. The FDA has specific regulations in each of these two scenarios.

“In the case of direct food contact such as a cereal in-box coupon, the printing inks must be formulated with special components that are in compliance with the FDA Indirect Food Additive Guidelines (CFR 21, 170-189). The very term the FDA uses, ‘Indirect Food Additive Guidelines,’ likely causes significant confusion in the industry since the term is used to regulate inks in direct food contact situations. Nonetheless, inks used in these situations must be comprised solely of approved components on the FDA’s list,” Sickinger says.

The FDA does not regulate the components of inks used in indirect food contact. Rather, the regulations stipulate that no substances may be transferred to the food itself unless they are approved under the Food Additive Guidelines. Sickinger explains, “Indirect food contact does not mean contact that occurs between a food product and a printed surface not intended for contact. Instead, indirect food contact refers to inks that are not intended to be in contact with food, but because of migration, inadvertently become part of the food product.”

FDA regulations for migration are very extensive and very specific. Migration into food products is accepted, but at very small levels, limited by the FDA in terms of parts per billion. In addition, all ink components that exhibit migration must meet testing specifications before being accepted as suitable for manufacturing.

Kurt Hudson, general manager, UV division, Water Ink Technologies, Lincolnton, NC, USA, says that there is so much misinformation out there regarding indirect food contact. “The first place to start in a discussion of indirect contact is actually a review of direct contact regulations. The FDA does not approve or disapprove specific packaging constructions, printing inks or coatings; instead, the FDA has established a listing of additives, compounds and materials which may be used in the manufacture of foods or for food packaging where direct contact may occur,” Hudson says, referring to the regulations set forth in the Federal Food, Drug and Cosmetic Act, and detailed in the CFR Title 21, sections 170-199.

Hudson says that the regulations governing indirect food contact are an extension of those for direct contact. “With regard to indirect food contact, contact is permitted provided that a functional barrier is used to separate the food from the printing or coating. Extraction limits for functional barriers are found in CFR 21. Here, the FDA states that if there is an approved functional barrier separating the inks and coating from the food, then they are not to be considered an additive. Therefore, the components of the inks and coatings do not need to be from the approved list of additives, compounds and materials,” he says.

Labels and packaging for food, Hudson says, usually utilize a label or packaging material itself as the functional barrier, which has three requirements. “The barrier must be made entirely of GRAS materials; it must consist of a select group of film, coating, or sheet products chosen for barrier properties; and it must pass an extraction test using water and/or solvent,” he explains, adding that many common films or sheet products used for labels and packaging are covered, such as polyethylene, cellophane, polystyrene, aluminum and many others.

Hudson says that Title 21 is an enormous document, written at different times by different authors from different perspectives on food packaging. “FDA legistlation for food contact is so overly comprehensive, it has become ambiguous,” he says. “It’s so difficult to wade through it all, which is a reason why some people shy away from working with food contact packaging,” he says.

According to Hudson, one issue marked by ambiguity is that of responsibility – the question of who’s to blame if something should go wrong. He says that the party that puts the product into the market is considered responsible, which is amibiguous considering all who are involved – retailers, brand owners, converters, and suppliers.

Hudson can’t emphasize enough the importance of scientific documentation. “You’d better know for a fact that all of the tests have been done on every aspect of the product. From the inception of our program we have had as a cornerstone a mission of providing far safer chemistry to the printing industry. Our program is the first and only one to require that all UV curable products are formulated to be free of aggressive skin irritants. In addition, all materials must be non-carcinogenic, non-fetotoxic and non-mutagenic. Still further, all inks are manufactured to be free of amines, and the odor and taint promoting chemical family, which includes benzophenone and benzophenone derivatives, offsets or related chemistries. The UV program at Water Ink Technologies is the only program in the world to standardize these features. Our philosophy is to do the testing and have a body of evidence,” he says.
Not only does it have to be determined if the label will come into direct contact with food, but it’s also imperative to know what kind of food, if there will be contact.

Allison Hazel, marketing manager for MACtac Printing Products, Stow, OH, USA, a supplier of pressure sensitive adhesives, says, “If the label will come in direct contact with food, printers need to know what specific type of food – meat, dried goods, fruit, etc. – in order to determine which materials meet the corresponding FDA regulations. The adhesive component of the label, which would come into direct contact with the food item, has to be submitted to the FDA for approval and MACtac offers a number of adhesives that comply with FDA CFR 21,” she says, adding that the company’s different offerings target a broad range of food-specific applications.

Hazel also notes that even if there should be no direct contact with food, printers should still be aware of the label’s proximity to food, its environment and the type of packaging it will adhere to. “Label location, from placement inside a box of dried food like cereal or rice to enclosure in another type of packaging material, like cellophane, affects the type of labeling material selected for the application because of regulatory compliance issues, as well as the requirements of the packaging environment,” she says, referring to a new set of issues that deal with moisture and extreme temperatures.

“Foods and beverages that need to be stored in cold or moist environments, like coolers, ice tanks or refrigerators, require packaging and labels that can withstand being cold, wet or frozen during food storage. These applications require a label with an all-temperature adhesive, like MACtac’s 640AT adhesive, or a label in the Glacier line that features MACtac’s 733 freezer-grade adhesive. The packaging itself is also an important factor for printers to consider in product selection because some types of waxy corrugated materials, like those used in poultry packaging, require an aggressive adhesive that will adhere to difficult substrates. MACtac’s newly launched TORQ line of specialty high-tack products was designed specifically to handle these traditionally difficult substrates,” Hazel says.

Inks are another area where testing must be application-specific. Mike Hoft, narrow web product manager for CRI, says, “In addition to environmental conditions, there are substrate considerations, as inks will typically exhibit different behaviors depending on the surface upon which they are printed. The analytical migration test procedures must simulate the time and temperature conditions that the product is going to be stored under, plus the food processing conditions of the manufacturer and consumer. Different test procedures will be used for a package that undergoes a cooking cycle, like a microwave popcorn bag or a ready-cooked meal versus a package that is simply frozen like a chub of hamburger. At CRI, we pride ourselves in formulating ink systems, keeping in mind where the label lives.”

In the end, keeping the lines of communication open and fully disclosing end use applications are key to successful food labeling. Frank Connelly of Western Shield says, “We consider the application environment and the service environment when recommending label materials for our customers. Certain adhesives are required for extreme cold or hot temperatures. Practically, we consider the temperature range and moisture level of the container surface at the point of application and during the service life of the label. These variables can dictate whether to use specific adhesives, varnish systems and/or laminations.”

Robert Petrie emphasizes the imperative nature of all involved in the printing process to work together. “As long as we work with our material suppliers to print labels on direct food contact materials, there are no issues. We are intentional about making sure that direct food contact labels are printed on the correct materials,” he says.

Healthy food

These days, discussions on most any business related topic will somehow lead to how the current economic downturn is effecting the industry. Labeling, and food labeling in particular, is no exception. However, reports out of this segment of the market are refreshingly postive. It’s easy to say “people will always need to eat,” but where and what they’re eating is noteworthy in regard to food labels.

The consensus among suppliers and converters alike, despite the economy, is that of a continuously growing segment of the market. Frank Connelly notes that when money is tight, people tend to spend more money at the grocery store in order to prepare food at home, rather than going out to eat. “The retail food market is relatively steady, but it is particularly strong in difficult economic times like these when consumers look to save money by eating more often at home rather than dining out in restaurants,” he says.

Laura Clark of Avery Dennison agrees, and she also says that the current economic strife consumers are going through plays a role in what’s appealing to them on the shelf as well. “Generally speaking, in recessions, most consumers will eat out less often, driving food sales at retail, which is good for the converting industry. When shopping for food, consumers look for the best deals, buy only what is needed, and will purchase brands which stress good value. I think the overall health of the industry is quite good, and branded products are looking for ways to differentiate themselves and reinforce their brand position. In the future, I expect both packaging and labeling to become a more important, critical component of the marketing mix,” she says.

MACtac’s Allison Hazel points to a growing population as a driving force in sustaining a healthy food labeling market. She emphasizes increased longevity and efforts to improve personal health as playing significant roles in food labeling’s growth. “As the population grows so will the variety of products offered in the food industry. Due to improvements in healthcare, the United States forecasts a 147 percent projected growth in the over 65 year old population between 2000 and 2050, creating a market for more diet-restricted products. Also, I think there will be an increase in smaller run digital labels that are used for test marketing and boutique grocery items. No matter the state of the economy, people continue to purchase food items and the population continues to increase, ensuring that the food labeling industry remains a steady market,” she says.

Regardless of the economy’s impact, food labeling is an interesting niche to discuss because it’s characterized by fierce competition. Branding is prevalent, and labels are on the front lines in trying to outsell rivals. End users will do whatever it takes to maximize shelf appeal.

“Since all the food manufacturers are fighting for attention on the shelf, it makes the label that much more important. To be vivid, eye catching, fit a product’s implied image, and says ‘make me stand out amongst my peers,’ is crucial to it’s success or failure,” says Peter Schambs, who adds that it’s a real balancing act to achieve those goals. “When constructing a brand’s label, we’re seeing companies use great care trying to balance the manufactured cost, the operating inventory, and the shelf appeal at the right levels. A misbalance on any of these levels has a great overall impact.”

Robert Petrie feels that quality, above all is else, is most importance when it comes to food labels. “An effective food label is a high quality label that is visually appealing, so in the food labeling niche, quality is the driving force – not price. You need to have a professional-looking label to differentiate your product from the rest of the competition. The label is a small element of the overall production cost, but it makes a tremendous impact.”
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