Packaging Materials

What

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

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:

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?

• Packaging plays an indispensable role in the circulation of commodities but is often overlooked, leading to the addition of prohibited and restricted substances. These packaging materials containing prohibited substances are often discarded after use, and the toxic substances they contain directly harm humans and the environment. Therefore, the EU, France, and the US have taken the lead in legislating, mandating that suppliers of packaging materials must provide materials that meet regulatory requirements.
• 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?

Note: TPCH is a model legislation that needs to be adopted and written into state laws by individual US state governments to be legally binding. For relevant legal provisions and implementation dates of each US state, please see the official TPCH website for details.

How

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