I believe that many peers are not unfamiliar with the compliance of packaging materials, but they often neglect the chemical requirements of packaging materials, because before that, the heavy metal restrictions on packaging materials in most regions were only for four types of heavy metals. For industries with relatively mature technical conditions, this is basically not a problem.
However, because the US TPCH has revised the restrictions on the chemical elements of packaging materials this time, the packaging material industry has experienced another bloody storm.
TPCH (Toxics in Packaging Clearinghouse), established in 1992, is responsible for promoting the Model Toxics in Packaging Legislation (Model Toxics in Packaging Legislation) to all states in the United States, and supporting and coordinating the implementation of the regulations. Due to the successful promotion of this regulation by TPCH, people often refer to the US regulations for the control of hazardous substances in packaging materials as TPCH. Previously, 19 states in the United States have adopted this law, which mainly requires that the heavy metals lead, cadmium, mercury, and hexavalent chromium not be intentionally added to packaging or packaging parts in any concentration, and when accidentally contained, the content of the four heavy metals The sum cannot exceed 100ppm.
On February 16, 2021, TPCH issued the 2021 updated "Model Regulations on the Control of Toxic Substances in Packaging Materials."
The main revisions include:
· Include phthalates and perfluorinated and polyfluorinated alkyl compounds (PFAS) in the list of controlled substances;
·Add new processes and standards for identifying and controlling highly concerned chemical substances in packaging;
· Revise the definition of "post-consumer recycled materials".
The 2021 updated "Model Regulations for the Control of Toxic Substances in Packaging Materials" issued by TPCH for hazardous substances control requirements for packaging and packaging components are as follows:
Harmful Substance:

Effective date of the regulation: February 16, 2021
other:
1. U.S. states can amend current regulations or adopt new regulations to implement TPCH's requirements for the management and control of new hazardous substances in packaging and packaging components.
2. For newly added substances under control, every state in the United States must introduce measures within 2 years from the effective date of this bill to prohibit the sale of packaging and packaging components that intentionally add hazardous substances controlled by the bill, and suggest that state legislatures revise this bill within 2 years Newly controlled substances are included in the state's list of prohibited chemical substances.
3. Manufacturers or suppliers of packaging and packaging components are obliged to provide a Certificate of Conformity (CoC).
The bill has officially entered into force on the date of issuance. Packaging materials are widely used in the electrical and electronic industries. Related companies need to pay attention to whether the content of hazardous substances in the packaging materials used meets the requirements of the updated "Model Regulations on the Control of Toxic Substances in Packaging Materials" to avoid Risk of non-compliance.
Let's learn about the next two kinds of material knowledge to be added together:
Phthalates (PAEs), also known as phthalates, collectively known as phthalates, are mainly used as plasticizers (plasticizers) and are added to plastics to enhance elasticity, transparency, Durability and longevity. Phthalates can also be used to soften polyvinyl chloride (PVC). Phthalates are the most widely used plasticizers with the largest variety and the largest output. When used as a plasticizer for plastics, it generally refers to an ester of phthalic acid and an alcohol with 1 to 15 carbons. Among them, dioctyl phthalate (such as DEHP) is the most important species.
Due to the hidden health risks of phthalates, the United States, Canada, and the European Union are gradually eliminating them from a variety of products.
Phthalates are used in a variety of products, such as enteric coatings for pills and nutritional supplements, viscosity agents, gelling agents, film aids, stabilizers, dispersants, lubricants, binders, emulsifiers and suspending agents Etc. Its application fields cover adhesives and glues, electronics industry, agricultural adjuvants, building materials, personal care products, medical equipment, detergents and surfactants, packaging industry, children’s toys, sculpture clay, wax, paint, ink , Coatings, pharmaceuticals, food and textile industries.
The hazards of perfluorinated and polyfluorinated compounds (PFAS)
On February 13, 2020, the British non-governmental organization Fidra released a survey report on perfluorinated and polyfluorinated compounds (PFAS) in FCM in the UK market. The results showed that the lunch boxes of 8 major supermarkets and take-out restaurants in the UK contained PFAS, and the fiber-molded take-out boxes contained the highest PFAS content. The report further aroused people's concern about the risks of PFAS.
PFAS is a type of man-made chemical substance, which refers to the compound containing C-F bond formed after the hydrogen atoms connected on the carbon chain of the organic molecules are fully or partially replaced by fluorine atoms. It can be divided into two types: non-polymer and polymer. Non-polymers include perfluoroalkyl carboxylic acids (PFCA), perfluoroalkyl sulfonic acids (PFSA), perfluoroalkyl sulfonamides (FOSA), fluorinated telomer alcohols (FTOH), perfluoroalkyls Phosphate esters (PAP), among which perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) are the two most widely used organic fluorides. PFAS has been widely used in industrial and consumer products such as chemicals, textiles, paper and packaging, coatings, construction products, and healthcare products since 1940 due to its unique inertness, hydrophobic and oleophobic properties, good sliding properties, and dirt repellency. field.
One of the main reasons why PFAS has caused widespread concern is that they are called "permanent chemicals", which means that once PFAS is released into the environment, they will not disappear easily. They have environmental persistence, long-distance mobility and biological properties. Cumulative. Studies in various countries have shown that dietary intake is the most important way of human exposure to PFAS. Among them, PFAS pollution introduced by food contact materials is an important influencing factor.
Existing toxicological studies have shown that PFAS can cause liver toxicity, developmental and reproductive toxicity, genetic and immunotoxicity, and carcinogenicity in laboratory animals. Some epidemiological investigations have also found that human exposure to PFAS is associated with the occurrence of certain diseases or cancers. . The U.S. Environmental Protection Agency (EPA) pointed out in 2016 that exposure to certain levels of PFOS and PFOA may lead to human health risks, including affecting fetal and infant development, cancer, liver damage, immune diseases, thyroid disorders, and cardiovascular diseases.
Common uses of perfluorinated and polyfluorinated compounds (PFAS)
In the field of food contact materials, PFAS is most widely used as a waterproof and oil-repellent coating for the production of polytetrafluoroethylene (PTFE), non-stick coatings and paper products. For example, PFAS surfactants (dispersants) are often used when producing fluororesin coatings that give kitchenware and paper products water and oil resistance and non-stick effects. And N-Ethyl Perfluorooctyl Sulfonyl Amino Ethanol (EtFOSE) is widely used in paper processing.
Studies have found that fluorine-containing or fluoride-treated food contact materials will remain and migrate out of PFAS during the production and use process, which may bring risks to food safety, consumer health and the environment. Begley and others tested PFOA residues in fast food packaging paper in the US retail market to be 0.2-1.4 mg/kg, while Thai and Chinese researchers also tested popcorn buckets, barbecue oil paper, hamburger wrappers, egg tart tin foil and other paper products. PFOA and other fluorides with varying concentrations are produced. In 2019, the IQTC laboratory detected PFAS such as perfluorooctanol and perfluorooctanol acrylate in more than 10 samples of commercially available paper products, with the highest content reaching 20 mg/kg. In addition, trace amounts of PFOS were detected in the three non-stick pan samples.
It is worth noting that recent studies have found that the residual and migration of typical PFAS such as PFOA and PFOS brought by food contact materials has been declining, while the perfluorinated compound alkane is an important raw material and intermediate of fluorinated surfactants. Precursors such as acids are more and more detected, and the amount of residue and migration are generally higher than that of PFOA, prompting the need to pay attention to the risk of PFAS precursors.
The update of the packaging material regulations will be a huge challenge for the majority of manufacturers exporting to the United States, especially those that use film. The editor understands that since the EU revised the restrictions on plastic products in 2019, many factories or brands have begun to update packaging, and most of them have replaced plastic packaging materials with other biodegradable materials.
In this way, you can avoid worrying about non-compliance because the packaging materials contain high-risk plastic materials.
So, as one of the manufacturers of products exported to the United States, have we all laid out?