TPCH Requests Comments on Proposed Updates to their Model Legislation for Packaging

The current Toxics in Packaging Clearinghouse (TPCH) (formerly known as CONEG) maintains the Model Toxics in Packaging Legislation which was developed in 1989 to provide consistent legislation across the states to reduce heavy metals in packaging and packaging components.  The Model legislation has been enacted in 19 states. 

As several states have begun to propose and enact their own legislation addressing other chemicals in packaging, specifically PFAS and phthalates, TPCH is proposing an update to their Model legislation to again promote consistency across the states. 

Requirement that remains unchanged:
• Lead, cadmium, hexavalent chromium and mercury must not be intentionally introduced into the packaging or packaging component and the sum of the concentration levels of the four metals incidentally present in the packaging components shall not exceed 100 ppm. 

Major changes include:
• Phthalates may not be introduced in the packaging or its components in any amount and the incidental concentration levels may not exceed 100 ppm.  Phthalates means all members of the class of organic chemicals that are esters of phthalic acid and that contain two carbon chains located in the ortho position.  A list of phthalates is not provided. 

• PFAS may not be intentionally introduced in any amount.  There shall be no detectable PFAS in any package or packaging components.  Perfluoroalkyl and polyfluoroalkyl substances or PFAS means all members of the class of fluorinated organic chemicals containing at least one fully fluorinated carbon atom.  A detection limit is not defined in the legislation. 

• Removes some of the current exemptions such as for vitrified labels and recycled materials. 

Comments may be submitted to info@toxicsinpackaging.org by August 24, 2020. 

To view the draft legislation:
https://toxicsinpackaging.org/?wysija-page=1&controller=email&action=view&email_id=11&wysijap=subscriptions&user_id=178 

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