Updated requirements for phthalates and PFAS in the US Packaging Directive TPCH!
Time:
2023-11-27
Updated requirements for phthalates and PFAS in the US Packaging Directive TPCH!
Recently, the Packaging Toxic Substances Exchange (TPCH) in the United States released a guideline document for the "Model Regulations on the Control of Toxic Substances in Packaging Materials" to support the implementation of the requirements for PFAS and phthalates in the Model Law.

About PFAS
The guideline document indicates that the best source of information on whether PFAS is intentionally added may be the manufacturer or supplier of the packaging. It is recommended to confirm whether PFAS is present in the product through the following three methods:
(1) Require suppliers to provide complete material disclosures;
(2) Require suppliers to disclose whether they intentionally added PFAS (if complete material disclosure cannot be provided);
(3) Looking for third-party certification.
If the supplier does not provide the required material disclosure information, test data can be collected to evaluate whether the product contains intentionally added PFAS, and the supplier can be asked first if there is any test data to prove it.
a. Regarding laboratory data: Suppliers can test the total fluorine content of packaging/products or components. If the result is below 100ppm and meets quality control standards, the product may not have intentionally added PFAS and may comply with the restrictions in the state packaging. If you find that the total fluoride content is low (even if they are below 100 ppm), we suggest that you contact the supplier to confirm that PFAS was not intentionally added; Identify unintentional sources of PFAS so that they can try to reduce or eliminate them; Determine the source of inorganic fluorine (not PFAS).
b. The total fluorine or total organic fluorine test results of a product or packaging equal to or greater than 100 ppm may indicate that the company or regulatory agency should conduct an investigation to determine whether PFAS has been intentionally added to somewhere in the supply chain.

Ortho benzene substances
At the same time, the guide also recommends using SW 846 method 8270 and EPA method 3541 to test phthalates, and lists some phthalates that are typically tested using the above methods:

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