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On Regulations

By AICC Staff

March 25, 2019

Many of the AskRalph inquires over the last 12 years have related to items on the list that follows. Now with a significant level of input from an Associate member, Zenna Dunn at Commencement Bay Corrugated, we submit the following rules, regulations, initiatives, and general-interest topics that may have an impact on the paperboard packaging you are producing. We will be expanding the list and adding more information for a white paper on these items. Ultimately, this is meant to be a living document even when it is placed on the website. While items on this list may not have a direct impact on your day-to-day operations today, they may be forward-looking and just interesting for your sales and marketing groups.

Tell us what is missing or inaccurate, please. This list is not comprehensive yet, nor is it alphabetical.

Forestry Certification

Sustainable Forestry Initiative Certification (http://www.sfiprogram.org/sfi-standards/)

Programme for the Endorsement of Forest Certification (www.pefc.org)

Forest Stewardship Council (https://us.fsc.org/en-us)

The State of America’s Forests by the U.S. Endowment for Forestry and Communities (https://www.usendowment.org/)

UN Sustainability Development Goals (http://www.undp.org/content/dam/undp/library/corporate/brochure/SDGs_Booklet_Web_En.pdf)

Plant Safety

Safety Data Sheets (https://www.osha.gov/Publications/OSHA3514.html)

Occupational Safety and Health Administration (https://www.osha.gov/)

National Fire Protection Association (dust) (https://www.nfpa.org/)

Bioterrorism Act of 2002: Compliance status with the Bioterrorism Act of 2002. To its knowledge, albeit paper roll products are exempted, compliance with FDA 21 CFR Section 182.90, 21 CFR Sections 176.170,176.180 and 21 CFR Section 176.260. (https://www.cbp.gov/trade/priority-/import-safety/bioterrorism)

Volatile Organic Chemicals or Materials (VOCs/VOMs), Hazardous Air Pollutants (HAPs), Air Toxic Chemicals regulated by Washington State, Extremely Hazardous Substances (EHS), CERCLA Hazardous Substances (HS), or EPCRA §313 Toxic Chemicals. (https://www.epa.gov/superfund/superfund-cercla-overview; https://www.epa.gov/toxics-release-inventory-tri-program/tri-listed-chemicals)

California SB 657 Transparency in Supply Chains Act Human Trafficking and Slavery (https://oag.ca.gov/SB657)

Trace metals statement of guarantee and metal detectors (https://askralph-aiccbox.org/2012/01/03/detecting-metal-in-corrugated/)

Food Regulations

FDA Food Contact Statement – Food and Drug Administration (FDA): 21 CFR Section 182.90, 21 CFR Sections 176.170 and 176.180, and Section 176.260. (https://www.fda.gov/food/ingredientspackaginglabeling/packagingfcs/regulatorystatusfoodcontactmaterial/default.htm)

UN HazMat Packaging Requirements 49 CFR 171–180 (https://www.ecfr.gov/cgi-bin/text-idxSID=028795e5b4a0b194cc473338c7237c13&mc=true&tpl=/ecfrbrowse/Title49/49CIsubchapC.tpl)

Heavy Metals: Conference of Northeastern Governors (CONEG) (https://www.coneg.org/resources/tpch/)

RoHS EU Directive 94/62/EC Article 11 (http://ec.europa.eu/environment/waste/packaging/legis.htm)

State of California Proposition 65. Safe Drinking Water Act Article 7 Section 12712(c) (1); and also, Reduction of Toxics in Packaging. (https://oehha.ca.gov/proposition-65/law/proposition-65-law-and-regulations)

Food Allergen Labeling and Consumer Protection Act of 2004 – to compliance with the provisions of FALCPA and EU Directive 2000/13/EC (https://www.fda.gov/Food/GuidanceRegulation/GuidanceDocumentsRegulatoryInformation/Allergens/ucm106187.htm)

Lacey Act 2008 Amendments (https://bit.ly/2U5ZJMJ)

HACCP: Hazard Analysis Critical Control Point is a management system in which food safety is addressed through the analysis and control of biological, chemical, and physical hazards from raw material production, procurement and handling, to manufacturing, distribution, and consumption of the finished product. This is administrated by the FDA. (https://www.fda.gov/food/guidanceregulation/haccp/)

Consumer Safety

Mineral Oil – We have written extensively on this in the AskRalph blog and past of BoxScore, which may be accessed through the search feature at www.aiccboxscore.org.

Consumer Product Safety Improvement Act (CPSIA): analysis for phthalates and lead content provided by CPSIA-accredited third party. (https://www.cpsc.gov/Regulations-Laws–Standards/Statutes/The-Consumer-Product-Safety-Improvement-Act)

U.S. Toxic Substances Control Act (https://www.epa.gov/laws-regulations/summary-toxic-substances-control-act)

Clean Air Act compliant (Title 6 – Stratospheric Ozone Protection) Ozone Depleting Chemicals (ODCs) Address Ozone Depleting Substances: Reference – Containerboard does not require warning labels, per Sections 611 and 612 of Title VI of the Clean Air Act, as amended in 1990. Content of Class I or II substances that are not directly manufactured in a process that uses a Class I or II substance. Also see 40CFR Part 82. (https://www.epa.gov/clean-air-act-overview/clean-air-act-title-vi-stratospheric-ozone-protection)

Animal Derived Materials “ADMs”: Kosher, Pareve, Passover or Halal Certification: Bovine Spongiform Encephalopathy/BSE/Mad Cow Disease, specifically free from beef tallow, or sourced from countries that are BSE-free (https://www.fda.gov/RegulatoryInformation/Guidances/ucm381379.htm)

“REACH,” (EU) Registration, Evaluation, Authorization and Restriction of Chemicals – Substance of Very High Concern (https://echa.europa.eu/regulations/reach/understanding-reach)

Endocrine Disrupting Chemicals – DEHA, DEHP, Bisphenol A, BADGE, Octyl Tin Compounds, Nonylphenol, or TNPP are not used as raw materials. EU directive on 68 compounds (https://ec.europa.eu/health/endocrine_disruptors/overview_en)

Canadian

Canadian Environmental Protection Act (CEPA) (https://www.canada.ca/en/environment-climate-change/services/canadian-environmental-protection-act-registry/related-documents.html)

Canadian Food Inspection Agency (http://www.inspection.gc.ca/eng/1297964599443/1297965645317)

Canadian Domestic Substances List (https://www.canada.ca/en/environment-climate-change/services/canadian-environmental-protection-act-registry/substances-list.html#toc0)

Plant Regulations

Environmental Protection Agency (https://www.epa.gov/)

Clean Water Act and individual states. (https://www.epa.gov/cwa-404/streams)

National Ambient Air Quality Standard (https://www.epa.gov/criteria-air-pollutants/naaqs-table)

Clean Water Act as administered by the EPA. (https://www.epa.gov/laws-regulations/summary-clean-water-act)

Vendor Certification

Amazon: Vendor Incentive Program, Amazon Standard Identification Number, USTA 6 Ships in Its Own Container Test, Frustration-Free Packaging Program, Prep-Free Packaging, Amazon Packaging Support and Supplier Network (APASS) (https://www.packagingdigest.com/supply-chain/amazons-packaging-vendor-incentive-program-crosses-the-pond-2018-11-1)

Trade Associations

AICC, The Independent Packaging Association (www.aiccbox.org)

American Forest and Paper Association (www.afandpa.org)

Fibre Box Association (www.fibrebox.org)

TAPPI (www.tappi.org)


PortraitRalph Young is the principal of Alternative Paper Solutions and is AICC’s technical advisor. Contact Ralph directly about technical that impact our industry at askralph@aiccbox.org.