TPCH releases US Packaging Directive guidance document

In November 2023, the Packaging Toxic Substances Clearinghouse (TPCH) published a guidance document on updated model toxicants in 2021 packaging legislation to support enforcement of PFAS and phthalate requirements.

The guidance proposes that the total fluorine content in the packaging/product/component can be tested. When the total fluorine is less than 100 ppm and meets quality control standards, the product is likely not to have PFAS intentionally added and may comply with state packaging restrictions. But even if the total fluorine content is less than 100 ppm, it is recommended to confirm with the supplier that no PFAS has been intentionally added.

It is recommended to confirm whether PFAS has been intentionally added to packaging/products by:

Ask suppliers for full material disclosure. If possible, ask for full material disclosure—a list of all the materials and substances in the components or material.
Ask suppliers to disclose if PFAS chemicals are added. If full material disclosure isn’t possible, ask if any PFAS chemicals are added.
Look for third-party certification: try to choose certified materials.

At the same time, the guide also recommends using SW 846 Method 8270 and EPA Methods Method 3541 (automatic Soxhlet/Soxhlet extraction) to test phthalate content. The following are phthalates commonly analyzed using SW 846 Method 8270:

Recommendation: Enterprises should fully conduct supply chain investigations based on the new version of the guidance document. When information disclosure is not possible, testing methods can be combined for effective control to determine product compliance and reduce product export risks.