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The Toxics in Packaging Clearinghouse (TPCH) has revised its sample Certificate of Compliance with the inclusion of a new declaration relating to the use of chemicals to replace regulated substances.

Adopted in 1989 by 19 US states, the Model Toxics in Packaging Legislation outlines the basic requirements for disposable packaging. The model states that the following four metals cannot intentionally be used above the threshold level of 100 ppm (in sum):

  • Lead
  • Cadmium
  • Mercury
  • Hexavalent chromium

Under the terms of the legislation, and other state laws, packaging suppliers, product manufacturers, and/or distributors must issue a Certificate of Compliance. This can be based on either the certificates of compliance issued by the suppliers of each packaging component or an analytical test report covering the four heavy metals in the packaging. Stakeholders must keep the Certificate of Compliance on file, although the length of retention for the record is dependent upon the individual state’s requirements.

The Model Certificate of Compliance declares:

  1. “We certify that the regulated chemicals – lead, mercury, cadmium, and hexavalent chromium -- were not intentionally added to any package or packaging component during the manufacturing process”
  2. “We further certify that the sum of the incidental concentration levels of lead, mercury, cadmium and hexavalent chromium present in any package or package component does not exceed 100 parts per million by weight”

In April 2020, TPCH added the following declaration:

  • “We further certify that no materials used to replace the regulated chemicals are present in a quantity or manner that creates a hazard as great or greater than the hazard created by the regulated chemicals”

Stakeholders are now advised to check their products continue to conform to the declarations in the sample Certificate of Compliance.

SGS Packaging Services

SGS is committed to providing information about regulatory developments in relation to packaging. Their global network of laboratories provides physical/mechanical testing, analytical testing, and chemical testing services, in addition to consultancy work, to help manufacturers ensure their products conform to national and international standards. Learn more about SGS Packaging Services.

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For further information contact:

Hsin Chen

Technical Manager - Restricted Substances

Tel:+1 973 461 7950



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