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Toxics in Packaging

The Model Toxics in Packaging Legislation and Our Solution

Toxics in Packaging: The Business Challenge

In today’s environment, consumers expect products to not only meet all federal and state regulations but to qualify as being “green” as well. This concern extends to the safety of product packaging and the potential for toxic substances to be present in them. Since 1989, nineteen US states have enacted legislation that prohibits the sale or distribution of packaging and packaging components that intentionally contain: lead, cadmium, hexavalent chromium, and mercury. Companies now find themselves responsible for compliance with not only what substances are in their products, but for substances found in their product packaging.

Toxics in Packaging: The Bureau Veritas Solution

The Toxics in Packaging Clearinghouse (TPCH) develops public policy actions regarding toxics in packaging and promotes the Model Toxics in Packaging Legislation. The legislation was first drafted by the Coalition of Northeastern Governors (CONEG) in 1989 with the intent to reduce the amount of lead, cadmium, hexavalent chromium, and mercury in packaging and packaging components from entering landfills, waste incinerators, recycling streams, and ultimately the environment.

What Does the Model Toxics Legislation Require?
• Manufacturers and distributors of packaging and packaging components are required to reduce the sum of the concentration levels of lead, cadmium, mercury and hexavalent chromium to the following levels:
– 600 parts per million, 2 years from enactment by the individual state
– 250 parts per million, 3 years from enactment by the individual state
– 100 parts per million, 4 years from enactment by the individual state.
Note: Most state laws were enacted in the early 1990s, so compliance with the 100 ppm has been mandatory for approximately 15 years. There are also exemptions that vary between state laws.

• Manufacturers and suppliers of packaging and packaging components are required to furnish a Certificate of Compliance to the purchasers of packaging. Certificates must also be furnished to state agencies and the public upon request.

• Comply with state requirements for toxics in packaging and meet the growing consumer demand for eco-friendly products
• Minimize the hazardous impact of products upon the environment and society
• Enhance risk management and brand protection


At Bureau Veritas, we are committed to helping you with a compliance program that meets your regulatory needs related to toxics in packaging. We will work with you to identify the most cost effective compliance solution for your products. This may include a combination of documentation and/or auditing as testing may not always be necessary.

We offer the following services:
Documentation Review: This review identifies the materials that must comply with the regulations and determines if the available certificates of compliance contain the appropriate information to demonstrate compliance as stated below.

Testing when documentation (Certificate of Compliance) is not available: When the appropriate documentation or Certificate of Compliance is not available, testing is performed to provide compliance documentation.

Auditing: Bureau Veritas can assist in setting up an audit testing plan to meet your needs to determine if appropriate documentation or certificates would be available from your vendors or manufacturers upon request, as required under the state laws. An audit program may be created to target high risk materials, high risk producers, new producers, or random products

Toxics in Packaging: Why Choose Bureau Veritas?

Reputation – For over 35 years, we have worked successfully with top manufacturers and retailers around the world to help them better manage risk and regulatory compliance.
Worldwide Locations – With locations close to sourcing areas in over 40 countries, we offer you the convenience of global coverage with local service.
Technical Knowledge & Leadership – Our staff is knowledgeable in a wide range of areas including chemical, analytical, packaging and engineering.
Personalized Service – At Bureau Veritas, we are committed to meeting your needs and providing you with the highest levels of service.

Toxics in Packaging: Frequently Asked Questions

  • What states have enacted legislation similar to the Model Legislation?

    Nineteen states: California, Connecticut, Florida, Georgia, Illinois, Iowa, Maryland, Maine, Minnesota, Missouri, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, Virginia, Washington and Wisconsin.

  • What is the definition of a package?

    “Package” is a container providing a means of marketing, protection or handling of a product and shall include a unit package, an intermediate package and a shipping container as defined in ASTM D996. “Package” shall also mean and include such unsealed receptacles as carrying cases, crates, cups, pails, rigid foil and other trays, wrappers and wrapping films, bags and tubs.

  • What is the definition of a packaging component?

    “Packaging component” means any individual assembled part of a package such as, but not limited to, any interior or exterior blocking, bracing, cushioning, weatherproofing, exterior strapping, coatings, closures, inks and labels.

  • If a product meets the European Union Packaging Directive (94/62/EC) toxic metal requirements, will it also comply with TPCH?

    The test methods and limits are the same, but the US state laws are stricter as they also prohibit the intentional use of any amount of the four restricted heavy metals.

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