Regulation Thresholds for EU Packaging and CONEG

Question Posed:

What are the threshold requirements for the EU Packaging (94/62/EC) and the US Toxics in Packaging Clearinghouse (CONEG) regulations?

Answer Provided:

The EU Packaging regulation requires minimal packaging that is easily recycled or biodegradable and sets recovery and recycling targets and deadlines for EU Member states. Concentration levels of heavy metals present in packaging the sum of concentration levels of lead, cadmium, mercury and hexavalent chromium present in packaging or packaging components shall not exceed 100 PPM.  Many EU member states require periodic reporting of imported packaging including quantity/weight, type and material of the packaging. These requirements vary depending on the member state.

Reference: http://eur-lex.europa.eu/legal-content/en/ALL/?uri=CELEX%3A31994L0062   

Note: Glass packaging is allowed to exceed 100 ppm when using recycled glass as long as the heavy metals are not intentionally introduced during the manufacturing process.

Reference: http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex:32001D0171

The US Toxics in Packaging Clearinghouse legislation was implemented by 19 US states (so far) to limit the presence of lead, cadmium, mercury and hexavalent chromium to less than 100 ppm within packaging. The manufacturers, suppliers and distributors are required to submit certificates of compliance stating that the packaging is in compliance with the requirements of the law for the signatory states and prohibits the sale or distribution of non-compliant packaging components, packaging or packaged product in signatory states.  

Reference:: http://toxicsinpackaging.org/model-legislation/model/

(this was the template legislation that made available to states to implement in their own jurisdictions.)

**Article contents are valid as of 2017-05-17

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