Packaging Compliance Regulation
Toxics in Packaging
Western supports the proper recycling, recovery and handling of waste associated with packaging. Western designs its molded fiber packaging components to reduce environmental impact and complies with laws designed to reduce toxics in packaging. In addition to its certification of compliance with those laws, Western’s testing shows that its packaging is substantially below the 100 ppm threshold for aggregate metals concentrations. Western also requires its suppliers of recycled feedstock to certify compliance with toxics in packaging laws. Western’s compliance certificate addresses the following:
CONEG CERTIFICATION/MODEL TOXICS IN PACKAGING COMPLIANCE The Toxics in Packaging Clearinghouse (TPCH) was formed in 1992 to promote the Model Toxics in Packaging Legislation. This model legislation was developed to reduce the amount of heavy metals in packaging and packaging components that are sold or distributed throughout the United States. Specifically, the law prohibits manufacturers from intentionally introducing mercury, lead, cadmium and hexavalent chromium to packaging products. Since packaging comprises approximately one-third of the waste stream, the goal is to reduce the amount of heavy metals entering municipal solid waste streams. The law allows manufacturers of packaging materials to use recycled feedstock as long as the incidental introduction of the four heavy metals totals less than 100 parts per million in aggregate. Manufacturers must certify that they meet the requirements of the law.
CALIFORNIA TOXICS IN PACKAGING PREVENTION ACT California enacted its Toxics in Packaging Prevention Act in 2006 and it mirrors the requirements in CONEG’s Model Toxics in Packaging legislation. The California law initially had exemptions to allow manufacturers to phase in the prohibition on metals, but most of the exemptions have now expired. The California law also requires the same certification as the Model Toxics in Packaging law.
EUROPEAN UNION’S DIRECTIVE ON PACKAGING AND PACKAGING WASTE (94/62/EC OF 20 DECEMBER 1994, AS AMENDED BY 2004/12/EC) AND THE CEN PACKAGING STANDARDS (2005/C 44/13) pertaining to heavy metals content requirements. — Commonly known as the Essential Requirements, the European Union passed a Directive that guides the design of packaging to minimize Environmental damage. The directive is about Minimizing the Amount of packaging used, avoiding use of Hazardous Materials in packaging, and making packaging Reusable, Biodegradable, or Recyclable where possible.
Certificates of Compliance
Manufacturers and suppliers of packaging and packaging components are required to furnish a certificate of compliance to customers upon request. This applies only to companies who actually put their products in the package and does not apply to the retailer or the individual consumer. The public and state also have access to these certificates. Click here to download Western’s Certificates of Compliance.
For further advice specific to our products and requirements, please contact Western and we will be pleased to discuss your needs.
Lacey Act
As part of its dedication to principles of responsible manufacturing, Western Pulp Products has incorporated Lacey Act compliance efforts into the sourcing and sale of all of its products and product lines.
The Lacey Act is a conservation law first passed in 1900. It has been amended by Congress several times, most recently in 2008. The 2008 Lacey Act amendments were aimed at preventing plant and wood products that have been illegally taken or harvested anywhere in the world from entering the commerce stream in the United States.
The 2008 amendments to the Lacey Act require all importers of plant and wood products to file declarations with the Department of Agriculture designating the nature and source of the imported product. Because Western Pulp Products does not directly import any plant or wood products into the United States, Western Pulp Products is not subject to the Lacey Act’s declaration requirements.
The 2008 amendments also prohibit the import, export, transport, sale, receipt, acquisition or purchase of any plant or wood product taken or harvested in violation of any domestic or foreign law. Civil and criminal penalties apply to violations of the Lacey Act done “knowingly,” and to violations that could have been prevented in the exercise of “due care.”
Although Western Pulp’s product line is made from pre-consumer and post-consumer recycled waste paper, Western Pulp is committed to meeting the Lacey Act’s objectives of preventing illegally sourced wood products from being trafficked in the United States. Western Pulp has not and will not knowingly transport, sell, receive, acquire, or purchase any wood product that has been illegally taken or harvested. Additionally, Western Pulp has implemented a Lacey Act “Due Care Program” to continually monitor its fiber supply in an effort to identify and sequester any wood products that fall under the prohibitions of the Lacey Act.
For more information about Western Pulp’s Lacey Act compliance efforts, contact our Corporate Office in Corvallis, Oregon.