2021 Proposed Update
TPCH Draft Model Legislation Update
In June 2020, the Toxics in Packaging Clearinghouse (TPCH) announced it is seeking comments on the organization’s draft update to their Toxics in Packaging Model Legislation. The update includes the addition of PFAS and phthalates as regulated chemicals, as well as new processes for identifying additional chemicals of high concern in packaging.
The current TPCH Model Legislation and laws enacted in 19 states prohibit the intentional use of cadmium, lead, mercury, and hexavalent chromium in any finished package or packaging component. The laws also limit the total incidental concentration of the four metals to 100 ppm.
Incidental concentration may result from the use of post-consumer recycled content to manufacture new packaging and components. The laws take a pollution prevention approach by prohibiting intentional use, and they place the primary burden of compliance on the supply chain by requiring manufacturers and suppliers to verify that the products they manufacture, sell, and use meet the requirements of the laws, maintain that documentation, and provide it to the public and units of government upon request.
Full Public Comments Received Now Available
The Toxics in Packaging Clearinghouse (TPCH) thanks everyone that submitted comments to the draft Model Legislation Update.
The next steps for TPCH are to finalize the update of the TPCH Model Legislation in response to comments received. Their response document will be posted here when available (January likely).
To learn more about this TPCH project, Click HERE to download the Call for Comments, Background Materials and the Draft Update to the Model Legislation