Under the Green Chemistry Initiative | California Considers Regulating Food Packaging

As part of the implementation of green chemistry and safe consumer goods management, California's Toxic Substances Control Department (DTSC) issued the "Three-year Priority Product Work Plan Draft (2018-2020)". It states that California will for the first time be 'transferred from consumer goods to food.' The treatment of hazardous chemicals in the '. DTSC selected a total of 7 categories of products, of which 5 categories have been implemented in the 2015-2017 plan, including:

(1) Beauty, personal care and hygiene products

(2) Cleaning products

(3) Home, school and office furniture and decorations

(4) Construction products and materials for construction and renovation

(5) Consumption office, school and business supplies

In addition, DTSC added two additional types of products - food packaging and lead-acid batteries. The two types of tea farmers previously planned for clothing products and fishing tackle will not be evaluated in this plan.

The plan pointed out that the inclusion of food packaging in one of the seven categories of products is due to concerns that the candidate chemicals therein are harmful to the human body or the environment. The following components of the food contact materials have been identified as candidate chemicals, including:

(1) Bisphenol A and Bisphenol S are components of the inner wall of plastic resin for food and beverage cans.

(2) Perfluoroalkyl and polyfluoroalkyl materials 'Create oil and waterproof coatings for food packaging'

(3) Phthalates used as plasticizers

(4) Styrene is 'a component of polystyrene and rubber products'.

Five non-governmental organizations have submitted comments supporting the plan's inclusion of food contact materials. They are: Environmental Health Center (CEH), Environmental Working Group (EWG), Clean Water Action (CWA), Breast Cancer Prevention Partners and Up Stream.

As a result of a law passed by the Governor of Brown and the California Legislature in 2016, lead-acid batteries are also planned. The inclusion of a class of products in this plan does not mean that they will be regulated or create any new legal obligations. It only represents that DTSC intends to evaluate products under this category as potential priority products.

So far, only children's foam pad sleep products containing tris(1,3-dichloro-2-propyl)phosphate (TDCPP) or tris(2-chloroethyl)phosphate (TCEP) have been formally The priority products are effective from July 1, 2017. There are two other products under consideration. They are unreacted MDI sprayed polyurethane foam and methylene chloride paint remover.

The priority product is a consumer product that is identified by the DTSC and contains one or more candidate chemicals. It requires the manufacturer to perform a substitute analysis in which they must consider potential alternative chemicals.

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