The use of printing inks for food packaging in the U.S. presents some interesting regulatory quandaries. Whereas substances that are expected to migrate to food are defined under the Federal Food, Drug, and Cosmetic Act of 1938 as food additives and require regulatory clearance by the U.S. Food and Drug Administration (FDA) for use (if not subject to an exemption), there is, in fact, no specific regulation that permits the use of a printing ink on packaging. There are certainly many instances in which a printing ink may be considered exempt from the need for regulation because it is not expected to migrate to food (such as a printed label on a canned food product). On the other hand, not everything that is printed on the outside of a food package can be considered to be separated by a functional barrier that will prevent its migration to food. What to do in this case? There is the rub!