EU Packaging Directive

Introduction to the EU Packaging Directive

Old Directive 94/62/EC

As early as 1994, EU member states had issued the Packaging and Packaging Waste Directive (94/62/EC, 2004/12/EC), which aims to ensure that packaging is suitable for collection, reuse, recycling, and promote energy recovery; Minimize the toxicity, danger, and environmental impact of packaging materials as much as possible; Minimize the weight and volume of packaging waste.

New Directive 2013/2/EU

On February 7, 2013, the European Union published Directive 2013/2/EU in the official gazette to revise Appendix I of Directive 94/62/EC on Packaging and Packaging Waste. This directive shall come into effect 20 days after its publication in the official gazette.

On February 2013, the EU revised Appendix I of 94/62/EC (Explanatory examples of the definition of packaging in Article 3 (1) of the EU Packaging and Packaging Waste Directive), adding 19, 4, and 2 explanatory examples to the example guidelines (i), (ii), and (iii) of Appendix I, respectively. These illustrative examples clarify the boundary between packaging and non packaging. Although the EU Packaging Directive has undergone multiple revisions, the management requirements for hazardous substances in packaging materials have not changed.

Control scope:

The directive covers all packaging and packaging waste in the EU market, whether from industrial, commercial, office, store, service, general household or other sources, regardless of the material used.

The test objects include:

Product packaging includes paper boxes, cardboard boxes, wooden frames, film boxes, plastic bags, bubble bags, foam, polystyrene, fasteners, thin sheets, ropes, coatings, ink, tape, glue, cable ties, labels, and instructions.

Controlled substances and limits:

Lead (Pb)+cadmium (Cd)+mercury (Hg)+hexavalent chromium (Cr VI)<100ppm

US Packaging Regulations TPCH (CONEG)

CONEG is a local regulation established in 1989 by the Northeastern State Governors Association (8 states) in the United States to reduce heavy metal content in packaging and packaging materials. With the establishment of TPCH in 1992, CONEG was also renamed TPCH. However, the TPCH testing method and requirements remain the same as CONEG, and the requirements for controlling products and toxic and harmful substances are basically consistent with those of the European Union.

What items should be tested for packaging materials and products?

Definition of Testing for Packaging Materials and Products

Packaging material and product testing refers to the process of conducting certain or various specialized tests on the protective quality and methods of materials and products used for manufacturing packaging containers, packaging decoration, packaging printing, packaging transportation, etc. that meet product packaging requirements.

Scope of testing for packaging materials and products

The testing of packaging materials and products can be divided into the following parts according to the type of material:

(1) Paper product packaging material testing

Testing of paper materials and products such as paper and cardboard. Paper materials and products are the most widely used series in production and daily life, and the quality of paper directly affects the quality of products. The testing of paper packaging materials includes several categories of performance, such as printing performance, mechanical performance, and weather resistance. Common quality issues with paper packaging materials include: the printing and mechanical properties of paper products do not meet product standards and usage requirements; Goods damage caused by poor weather resistance; Paper products release harmful substances, causing contamination or damage to the products.

(2) Plastic packaging material testing

Testing of plastic packaging materials and products. Plastic packaging is also an important type of packaging used in our daily lives, second only to paper. The testing items for plastic packaging materials mainly include: mechanical properties (tensile, tear, puncture, etc.), barrier properties (moisture resistance, oxygen resistance, etc.), weather resistance, optical properties, anti-static properties, foam material cushioning properties, etc.

Common quality issues with plastic packaging materials include: insufficient mechanical and barrier properties; The weather resistance test shows phenomena such as discoloration, brittleness, melting, adhesion, cracking, etc; The light transmittance and ultraviolet transmittance do not meet the standards; Abnormal values of surface resistance and poor buffering performance of materials were observed during testing in specified environments.

(3) Testing of wooden packaging materials

Wooden packaging material testing refers to the testing of wooden materials such as wood and artificial board products used for supporting, protecting, or transporting goods. The testing items for wooden packaging materials mainly include: static bending strength, flexural strength, bonding strength, nail holding strength, moisture content, formaldehyde emission, weather resistance, etc.

Common quality issues with wooden packaging materials include: board breakage; Rusting of products caused by high moisture content in wood; Formaldehyde release and harmful gas release, etc.

(4) Composite packaging material testing

Composite packaging material testing is aimed at two or more materials that are combined together through one or more composite processes to form a composite material with certain functions. The testing items for composite packaging materials mainly include barrier properties, mechanical properties, weather resistance, light blocking properties, anti-static properties, etc.

Common quality issues with composite packaging materials include: barrier properties (moisture and oxygen permeability) and mechanical properties that do not meet the required standards; Aluminum foil bags and aluminum plated bags have poor light blocking properties; Surface resistance and other electrical properties do not meet the standards.

(5) Food packaging testing

Food packaging has the function of protecting food, preventing damage from external factors such as biology, chemistry, and physics during circulation, and maintaining the stable quality of food itself. It not only facilitates the consumption of food, but also has the effect of showcasing the appearance of food and attracting consumption, enhancing product value. Common food packaging materials include paper, plastic, wood, glass, metal, etc.

EU updates specific ROHS 2.0 exemption clauses

On February 5, 2019, the European Commission issued a batch of directives (EU) 2019/169 to (EU) 2019/178, updating 9 items and adding 1 exemption clause to Appendix III of RoHS 2.

On February 5, 2019, the Official Journal of the European Union (OJ) released a batch of revised directives (EU) 2019/169 to (EU) 2019/178, which updated the exemption clauses in Appendix III of the RoHS Directive (2011/65/EU).

These revisions cover various applications of materials and components containing lead and cadmium, including:

Lead in specific applications such as dielectric ceramics, solder, fluorescent powder catalysts, printing inks, etc

Cadmium in specific electrical contacts and printing inks

Directive (EU) 2019/169 to (EU) 2019/177 provide more detailed definitions of exemption scope and update the validity period, while Directive (EU) 2019/178 adds a new exemption for lead in specific applications (Article 42).

These revisions will take effect 20 days after their publication in the Official Gazette (OJ), and member states are required to adopt these updates before March 1, 2020, but the newly added "Article 42" will be implemented from July 22, 2019. Table 1 summarizes the updated RoHS exemption clauses.

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