Packaging Products Restricted Substance Testing

EU Packaging Directive:

The EU Packaging Directive 94/62/EC, titled "Directive of the European Parliament and of the Council on Packaging and Packaging Waste," applies to all packaging and packaging waste placed on the EU market. This includes packaging used in industrial, commercial, office, retail, service industries, households, or other locations, regardless of the materials used. All such packaging must comply with the control requirements of the EU Packaging Directive.

US TPCH:

In 1992, GONEG established the Toxics in Packaging Clearinghouse (TPCH) to promote the Model Toxics in Packaging Legislation across the US and support its implementation. Currently, TPCH's packaging toxicity regulations have been adopted by 19 states, restricting the entire packaging supply chain, including manufacturers, suppliers, and product producers or distributors using packaging. Initially, TPCH regulated only four heavy metals, but in February 2021, TPCH released updated regulations. The new regulations introduced control requirements for per- and polyfluoroalkyl substances (PFAS) and phthalates. Given its wide influence in the US, packaging for products exported to the US is often required to comply with TPCH requirements.

2. Evaluation Standards

The evaluation standards for packaging products include:

- EU Packaging Directive 94/62/EC

- US TPCH

3. Testing Items and Limits

EU Packaging Directive: 

- Substances: Lead, Mercury, Cadmium, Hexavalent Chromium 

- Limit: Total ≤ 100 ppm 

- Applicable to: Packaging and packaging components 

US TPCH: 

- Substances: Lead, Mercury, Cadmium, Hexavalent Chromium 

  - Limit: Total ≤ 100 ppm 

- Substances: Phthalates 

  - Limit: Total ≤ 100 ppm 

- Substances: Per- and Polyfluoroalkyl Substances (PFAS) 

  - Limit: Prohibited 

4. Solutions

To address compliance requirements, the following solutions are recommended: 

1. Testing of substances controlled by the EU Packaging Directive and US TPCH. 

2. Risk assessment of materials to ensure compliance. 

3. Training and consulting services for internal teams and supplier compliance management. 

4. On-site audits of packaging-related hazardous substances regulations for internal operations or suppliers.