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Toxics in Packaging Testing

Hazardous Substance Regulations are affecting a wide number of industries and product lines; including the manufacturers of packaging.  Below is an overview of the Toxics in Packaging Law, please contact Skyray XRF to discuss your testing needs. 
2009 Update from the Toxics in Packaging Clearinghouse (click for pdf)

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Toxics in Packaged Goods - plastic bagsWhat is the definition of packaging?
In the context of legislation, the brief definition of "package" is a container providing a means of marketing, protection or handling of a product.

This includes such unsealed receptacles as carrying cases, crates, cups, pails, rigid foil and other trays, wrappers, etc.  Also important to note is the definition of "packaging component"; which is any individually assembled portion of a package such as any interior or exterior blocking, bracing, cushioning, weatherproofing, exterior strapping, coatings, closures, inks and labels.

Why is regulation required?

To reduce the amount of toxic metals used in packaging materials that enter landfills, waste incinerators, recycling streams and, ultimately, the environment. In a recent study by the Toxics in Packaging Clearinghouse (TPCH) 16% of packaging that was randomly selected for testing exceeded the content levels defined by regulations (100 ppm).


Is X-Ray Fluorescence accepted as a testing method?
The TPCH study (referenced above) utilized portable x-ray fluorescence (XRF) technology to test a wide variety of packaging materials. It also compared portable and bench-top XRF (inexpensive, non-destructive) testing options to inductively coupled plasma (ICP) spectrometers (costly, destructive test method) and based on its assessment, "TPCH and its member states support the use of XRF technology to screen packages and packaging materials for compliance with state requirements."


What metals are regulated and what is the legislation?
The Model Toxics in Packaging Legislation was originally drafted by the Source Reduction Council of CONEG in 1989 and versions have been adopted by several states. The goal of legislation and regulation is to reduce the amount of heavy metals in packaging and packaging in components sold or distributed throughout the United States.

Toxics in Packaged Goods - consumerAs agreed to through a collaborative effort between states and industry, the legislation regulates the sum amount of lead, mercury, cadmium and hexavalent chromium in packaging and its components. Through a yearly decrease in the allowable parts per million (ppm) levels of the metals the current sum amount of all four metals can not exceed 100 ppm.

Since being developed, legislation has been adopted by nineteen states: California, Connecticut, Florida, Georgia, Illinois, Iowa, Maine, Maryland, Minnesota, Missouri, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, Virginia, Washington and Wisconsin. Enforcement policies and exemptions are determined by the individual state.

Who is affected by toxics in packaging regulations?

The legislation primarily affects manufacturers and suppliers of packaging and packaging components sold into regulated states. However, the product manufacturers, distributors and retailers that use packaging (as part of finished goods) must also show compliance or utilize compliant packaging.


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