Testing Services

Packaging Materials

 

EU and US Packaging Materials Prohibited and Restricted Substances Testing Services

 

What

What are the current international requirements for prohibited and restricted substances in packaging materials?

  Packaging and Packaging Waste
(EU)2025/40
French Packaging Requirements and Prohibition
R543-43 ~ R543-74
US Toxics in Packaging Clearinghouse (TPCH)
1 Cadmium (Cd) Cadmium (Cd) Cadmium (Cd)
2 Lead (Pb) Lead (Pb) Lead (Pb)
3 Mercury (Hg) Mercury (Hg) Mercury (Hg)
4 Hexavalent Chromium (Cr6+) Hexavalent Chromium (Cr6+) Hexavalent Chromium (Cr6+)
    Mineral Oil (MOSH) Perfluoroalkyl and polyfluoroalkyl substances (PFAS)
    Mineral Oil (MOAH) Phthalates

Who

Who needs to comply with hazardous substance requirements for packaging materials?

Businesses importing packaging materials into the EU market, the French market, or the US market. Packaging materials can be made of any material, as long as their primary purpose is to contain and protect goods, facilitate handling and transportation, and ensure that products are delivered intact from the producer to the consumer or end user. All such items are considered packaging materials. For example

For example:

Product Cardboard Boxes Cartons Wooden Frames
Film cases Plastic bags Bubble bags
Foam Styrofoam Fixing devices
Adhesive tape Glue Cable ties
Sheets/Plates Ropes Coatings
Inks Labels User manuals

If you are unsure whether your product belongs to packaging materials or which testing items are needed, please feel free to discuss with us.

Why

Why comply with hazardous substance requirements for packaging materials?

  • The successful promotion of EU PPWR, French packaging regulations, and US TPCH regulations has a strong influence across international markets; therefore, regulatory authorities in various regions use them as legislative standards.
  • Among them, French packaging and US TPCH requirements are unique. In addition to requiring that products do not contain prohibited substances, manufacturers, wholesalers, and suppliers must provide a Certificate of Compliance (COC) to packaging purchasers. If TPCH is violated, it should be noted that each US state handles it differently. For example: Connecticut, USA: A fine of USD 10,000 for each violation; if the COC certificate is inconsistent with the facts, the fine for false claims is USD 25,000.

Note: Common false claims in COC certificates include the concentration of prohibited substances being inconsistent with facts, or incorrectly claiming one's product as an exempt item.

When

When will it be officially implemented?

Packaging and Packaging Waste
(EU)2025/40
French Packaging Requirements and Prohibition
R543-43 ~ R543-74
US Toxics in Packaging Clearinghouse (TPCH)
  • Effective from 2025/2/11
  • Applicable from 2026/8/12, repealing Directive 94/62/EC
  • Officially implemented on January 1, 2022
  • CONEG officially implemented in 1989
  • CONEG officially renamed to TPCH in 1992
  • New revision officially implemented on February 16, 2021

How

How to comply with prohibited and restricted substance testing for packaging materials?

To Do List SGS Total Solution
Credibility of supplier test reports SGS Prohibited & Restricted Chemical Substances Cloud Service Platform verifies report authenticity
Confirm presence of regulated hazardous substances before shipment SGS provides testing services for various packaging materials
Establish a green supply chain management system SGS assists in establishing green supply chain management systems, importing ESG concepts and creating relevant documents.
Product design considering circular economy SGS provides product R&D engineering optimization solutions
Prepare a Declaration of Conformity (EU DoC) or Certificate of Conformity (TPCH COC) for Packaging Materials. SGS provides packaging regulation training
Save time and money SGS provides expert technical discussions and analysis of component differences
Stay updated on the latest regulatory developments Join the LINE account "e-Garden" (e電園)

References:

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