UV/EB coatings are regulated in the European Union (EU) and the U.S. as any other component of a food packaging material. In the U.S., this means that the coating must be covered by an applicable FDA regulation, FCN, or otherwise cleared for use. If a coating is not cleared under an appropriate regulation, a Food Contact Notification (FCN) to cover the use of the UV/EB cured coating must be submitted to FDA. In addition to the administrative, chemistry, and toxicology information typically required in an FCN submission, the notification also should demonstrate that the UV/EB curing process does not result in additional migrants or otherwise create degradation products that raise a safety concern. In the case of a UV cured coating, any free radicals generated from the degradation of the photoinitiator should be accounted for in an FCN, and sufficient data should be submitted to support the safety of those substances at their detected levels in the cured coating. The EU does not have a directive concerning paperboard for use in food packaging. Therefore, the use of coatings on paperboard is subject to individual member state requirements.

In response to your second question, while there are more water-based coatings cleared for use on paperboard than UV-based coatings, legally speaking, there is no advantage to using one over the other, and FDA will certainly consider permitting the use of a UV-based coating, provided that it is shown to be safe for its intended uses.