Toxics in Packaging

Guidance on Laboratory Analysis for Toxics in Packaging

An document associated with the Round Robin Test Project, this document will provide guidance for manufacturers, suppliers, retailers, and analytical testing laboratories for measuring heavy metals in packaging. This document, Guidance on Laboratory Analysis for Toxics in Packaging, is also available on the TPCH website.

Introduction

On January 1, 2006, California laws went into  effect that limit cadmium, lead, mercury, and hexavalent chromium in product packaging.

DTSC is taking a proactive approach to limiting these metals in our environment through:

• Educating businesses and consumers regarding potential toxic metals in packaging; and
  
• Eliminating these toxic metals prior to manufacturing.

By limiting or removing these metals from packaging, they do not become an environmental or health problem later when this packaging eventually reaches the consumer, who uses the packaging and then discards or recycles it. These laws are very far-reaching, and include ANY packaging or packaging component sold in California. These laws affect all manufacturers, distributors, and resellers, regardless where the packaging was made, distributed from, or sold from. If it is eventually sold or distributed in California, then these laws apply.

Examples of some, but not all, packaging covered by this law:

• Food overwrap for food products sold in retail channels
• Plastic clamshells that hold a product
• Cardboard used to protect laptop computers
• Steel strapping used to secure shipping containers
• Recycled materials used to make new packaging

Fact Sheets

Preventing Toxic Substances in Packaging

This fact sheet contains detailed information on the law, exemptions, and compliance. This fact sheet is all-inclusive for all audiences.

Toxics in Packaging Exemptions Expiring January 1, 2010

This fact sheet explains the exemptions in the Toxics in Packaging Prevention Act that are expiring on January 1, 2010. Although written for manufacturers and suppliers, the information in the fact sheet also applies to purchasers of packaging that is affected by these changes.

Toxics in Packaging Information for Manufacturers and Suppliers

If you manufacture or supply packaging or packaging components, this brief fact sheet will give you some basic information about the Toxics in Packaging Prevention Act, and what you need to do to comply with this law.

Toxics in Packaging Information for Purchasers

If you purchase packaging or packaging components, this brief fact sheet will give you some basic information about the Toxics in Packaging Prevention Act, and what you need to do to comply with this law.

The Toxics in Packaging Prevention Act:  A Fact Sheet for Grocers and Retailers on Bags and Totes

If you are a grocer or retailer, there are some things you need to know about the Toxics in Packaging Prevention Act, and the bags and totes you use.

Certificate of Compliance

On and after January 1, 2006, each manufacturer or supplier shall furnish a certificate of compliance to the purchaser of a package or packaging component stating that the package or packaging component is in compliance with the requirements of the Toxics in Packaging Prevention Act. A copy of the certificate of compliance shall be kept on file by the manufacturer or supplier of the package or packaging component. DTSC may request a copy of the Certificate of Compliance.

A sample Certificate of Compliance may be obtained here. This is not an actual Certificate of Compliance. This needs to be placed on company letterhead, and must be signed by an authorized official of the company issuing the Certificate.

Other Resources

Toxics in Packaging Clearinghouse (TPCH)

The Toxics in Packaging Clearinghouse (TPCH) just released the first comprehensive report on the presence of toxic heavy metals in packaging. The TPCH screened packaging samples for the presence of four restricted metals (lead, cadmium, mercury, and hexavalent chromium) using a portable NITON x-ray fluorescence (XFR) analyzer. The project was supported by a grant from the U.S. Environmental Protection Agency.

The full report, "An Assessment of Heavy Metals in Packaging: Screening Results Using a Portable X-Ray Fluorescence Analyzer", as well as other information, can be downloaded from the TPCH web site at www.toxicsinpackaging.org.

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Contact us with questions or comments tipinfo@dtsc.ca.gov

Last updated July 28, 2011