US Draft Amendments to Toxic in Packaging Model Legislation

The Toxics in Packaging Clearinghouse (TPCH) is seeking comments on the draft update to Toxic in Packaging Model Legislation. Legislation based on this Model has been adopted by 19 states. The followings are the highlight:

1. In the existing legislation, the sum of concentration of lead, cadmium, mercury or hexavalent chromium in packaging and its components shall be less than 100 ppm (0.01%). In addition to the existing requirements, the followings requirements shall be newly added:
   1. The limit of phthalate content in packaging and its components shall be less than 100 ppm (0.01%).
   2. Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) shall not be found in packaging or packaging components.
2. The following exemption shall be removed:
   1. Date of package manufacture
   2. Vitrified labels testing criteria
   3. Reusable packaging in closed loop system with end of life recovery
   4. State option for higher metals content due to recycled materials
3. A list of packaging chemical of high concern will be published and reviewed periodically by the state administrative agency.