California Adopts New Food Contact Packaging Restrictions and Cookware Labeling Requirements

California introduces regulations to
restrict perfluoroalkyl and polyfluoroalkyl substances (PFAS) in food contact
materials and articles derived from plant fibers. The law also requires the
disclosing of designated chemicals contained in cookware.

The State Governor sighed AB 1200 into law
on October 5, 2021. It adds a new Chapter 15 ‘Chemicals of Concern in Food
Packaging and Cookware’, commencing with Section 109000, to the state’s Health
and Safety Code in Part 3 of Division 104.

Under the terms of the law, PFAS will be restricted
to less than 100 ppm (as total organic fluorine). PFAS are a family of
fluorinated organic chemicals containing at least one fully fluorinated carbon
atom. It applies to food packaging that is substantially made of paper,
paperboard, or from materials using fibers derived from plants and includes
eating utensils, food boxes, food or beverage containers, liners, serving
vessels, straws, take-out food containers, unit product boxes, wrappers and
disposable plates, bowls and trays.

The law also requires the disclosure of
specified chemicals contained in the cookware handle or surfaces that may come
into contact with food, foodstuffs or beverages. The designated list contains
substances that have been identified as candidate chemicals, exhibiting a
hazard trait or an environmental or toxicological endpoint that meets the
criteria in regulations adopted by the Department of Toxic Substances Control (DTSC)
pursuant to Article 14 (commencing with Section 25251) of Chapter 6.5 of
Division 20. This is published on the DTSC’s website.

Disclosure must be done online (in the
sale listing) and/or on the product label.

Online disclosure requires:

  1. List of designated
    chemicals contained in the cookware
  2. Names of
    the authoritative list(s) referenced by the DTSC in compiling the designated
    list on which each chemical is present
  3. Link to
    internet website for the authoritative list(s) in point 2

[if !supportLists]

Product labels should contain the
introductory phrase, ‘This product contains:’, followed by a bi-lingual
statement (English and Spanish) reading ‘For more information about chemicals
in this product, visit’. This must then be followed by both of the following:

  1. Internet
    website address or a web page that provides all of the information in online
  2. Quick
    response (QR) code or other machine-readable code, consisting of an array of
    squares, used for storing an internet website for a web page that provides all
    of the information in the online disclosure requirements

[if !supportLists]

Cookware exemptions must meet both of
these criteria:

  1. Surface
    area of the cookware is less than 2 square inches
  2. Cookware
    does not have:

    • Exterior
      container or wrapper on which a product label can appear or be affixed
    • Tag or
      other attachment with information about the product attached to the cookware

[if !supportLists]

Cookware is defined as durable and used in
homes and restaurants to prepare, dispense, or store food, foodstuffs, or
beverages – includes baking molds, baking sheets, bowls, grills, pans, pots,
skillets, trays and cooking utensils.

The new regulations come into effect on
January 1, 2023.

SGS Food Contact Materials Services

SGS’s technical experts have extensive experience of testing materials and
articles in contact with food. They can ensure that your products meet the
appropriate regulations for food contact materials and pave the way for
compliance. SGS offers the full range of testing, including migration tests,
along with expert advice on emerging regulations, compliance issues and
documentation review. In the end, it’s only trusted because it’s tested.
Learn more about SGS’s Food Contact
s Services.

SGS SafeGuardS keep you up to date with the
latest news and developments in the consumer goods industry. Read the full California,
USA, Regulates PFAS in Certain Food Packaging and Requires Information for

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For further information contact:

Dr. Hingwo Tsang

Global Information and Innovation Manager

Tel: (+852) 2774 7420



LinkedIn: sgs-consumer-goods-&-retail

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