CA TPPA: Toxics in Packaging Compliance Guide¶
The Toxics in Packaging Clearinghouse (TPCH) — a coalition of 19 US states — regularly screens packaging for restricted heavy metals and publishes its findings. In its most recent screening report, the TPCH found that packaging from several major brands and retailers contained cadmium and lead above the 100 ppm threshold, with the highest concentrations appearing in inks, pigments, and plastic colorants rather than the base packaging material itself. This matters because the enforcement target is shifting: it is no longer enough to certify the substrate. Every component layer — inks, coatings, adhesives — must independently comply.
The California Toxics in Packaging Prevention Act (TPPA) — codified at Health and Safety Code §§ 25214.11–25214.26 — prohibits the intentional use of cadmium, lead, mercury, and hexavalent chromium in any packaging or packaging component sold or distributed in California. Nineteen other states have adopted identical legislation through the TPCH model. On the Sustalium platform, we see TPPA compliance appearing most frequently in packaging declarations for consumer goods, cosmetics, and food products — sectors where California distribution is essentially guaranteed and the multi-state nature of the requirement means companies must comply across a patchwork of state laws with a single, consistent Certificate of Compliance.
What the TPPA Regulates¶
The TPPA covers any container, wrapping, or material used to hold, protect, or market a product — including:
- Boxes, cartons, crates, trays, and pallets
- Bags, wrappers, and flexible films
- Clamshells, blister packs, and thermoforms
- Labels, stickers, and hang tags
- Ink, dye, pigment, and coating applied to packaging
- Adhesives, stabilizers, and any additive incorporated into packaging material
The law applies to the packaging AND each individual component — meaning that the ink on a cardboard box and the adhesive on a label are independently subject to the same limits.
The Four Restricted Metals¶
| Metal | Common Sources in Packaging |
|---|---|
| Lead (Pb) | PVC stabilizers, pigments (yellow, orange, red), inks, solders |
| Cadmium (Cd) | Pigments (yellow, orange, red), PVC stabilizers, plating |
| Mercury (Hg) | Biocides in paper, pigments (historically), intentional use rare |
| Hexavalent Chromium (Cr VI) | Corrosion inhibitors, pigments, plating |
The Threshold¶
The TPPA prohibits the intentional introduction of any of the four metals into packaging. For incidental presence — trace contamination that is not intentionally added — the sum of the concentrations of all four metals must not exceed 100 parts per million (ppm) by weight.
This is a low threshold. A packaging component with 30 ppm lead from pigment, 40 ppm cadmium from a stabilizer, and 35 ppm hexavalent chromium from plating — all individually below 100 ppm — would still violate the law because the sum (105 ppm) exceeds the aggregate limit.
The Certificate of Compliance¶
The TPPA requires every manufacturer, distributor, and supplier of packaging to furnish a Certificate of Compliance to the purchaser. The certificate must state that the packaging complies with the TPPA. While the law does not prescribe a specific format, a defensible Certificate of Compliance should include:
- Issuer identification: Legal name and address of the entity certifying compliance.
- Product and packaging description: Sufficient detail to link the certificate to the specific packaging — SKU, component name, material composition.
- Statement of compliance: An affirmative statement that the packaging and all its components comply with the TPPA (and, as applicable, the TPCH model legislation) and do not contain intentionally added cadmium, lead, mercury, or hexavalent chromium, with the incidental sum of these four metals below 100 ppm.
- Testing basis: Reference to test methodology (e.g., EPA Method 3050B/3051A for digestion and EPA Method 6020/6010 for ICP-MS/ICP-OES analysis) and the accredited laboratory that performed the testing.
- Date and signature: Date of issue and signature of an authorized representative.
The 19-State TPCH Framework¶
While California's TPPA is the most commonly referenced, 19 states have adopted the TPCH model legislation. The state list includes California, Connecticut, Florida, Georgia, Illinois, Iowa, Maryland, Minnesota, Missouri, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, South Carolina, Vermont, Washington, and Wisconsin.
The critical operational point: a Certificate of Compliance issued for California TPPA covers the same four metals and same 100 ppm threshold as every other TPCH state. A single well-documented certificate satisfies all 19 states — but the certificate must be available on request for any state.
The PFAS and Phthalate Expansion¶
In 2021, the TPCH updated its model legislation to add perfluoroalkyl and polyfluoroalkyl substances (PFAS) and ortho-phthalates to the list of prohibited substances in packaging. As of 2026, not all 19 states have adopted the update into their own laws, but the direction is clear. Packaging suppliers preparing compliance documentation now should include PFAS and ortho-phthalate testing even if their state has not yet adopted the update — because the buyer requesting the Certificate of Compliance may be located in a state that has, or may anticipate the requirement.
How Sustalium Supports TPPA Compliance¶
Managing component-level metal testing, generating multi-state Certificates of Compliance, and maintaining current versions as materials or suppliers change is a documentation burden that grows quickly with product variety.
Sustalium's CA TPPA compliance platform addresses this:
- Component-Level Declaration Builder: Enter your packaging materials and each component — substrate, ink, coating, adhesive, label. Sustalium structures a Certificate of Compliance that covers every layer, including test methodology and lab accreditation details.
- Multi-State Compliance Mapping: The platform automatically maps your TPPA certificate against the requirements of all 19 TPCH member states and flags any state-specific additional requirements (such as adopted PFAS or phthalate provisions) that your certificate should address.
- Testing and Re-Testing Triggers: Sustalium links your test reports to each packaging SKU and provides automated reminders when testing is due for renewal — reducing the risk of an expired test report supporting an active Certificate of Compliance.
- Buyer-Ready Verification Pages: Instead of emailing static PDFs to every purchaser that requests them, generate a public compliance page that retailers and brand buyers can access directly to verify your packaging compliance. This is particularly valuable for suppliers serving multiple downstream customers, where the same certificate needs to be shared with dozens of buyers.
Cover Your Packaging Across 19 States with One Certificate
Don't rely on a static PDF stored in a procurement folder. Generate a structured, verifiable Certificate of Compliance that covers California TPPA and all 19 TPCH states — and share it instantly with every buyer that asks.
With Sustalium, build your TPPA Certificate of Compliance for just €10 per document.
Frequently Asked Questions¶
Does the TPPA apply to packaging used for B2B shipments?
Yes. The TPPA applies to all packaging sold or distributed in California — including B2B packaging, industrial packaging, pallets, and shipping materials. The only exemption is for packaging that is reused, where the manufacturer has a documented take-back and reuse program.
Is a single Certificate of Compliance sufficient for all 19 TPCH states?
Yes, for the four heavy metals, a single certificate referencing the 100 ppm aggregate limit satisfies all 19 states. However, states that have adopted the 2021 expansion to include PFAS and ortho-phthalates may require additional certifications for those substances.
How often must packaging be tested for TPPA compliance?
The law does not specify a fixed testing frequency, but a Certificate of Compliance must be based on reasonable and current testing. Industry practice is to re-test when the material composition, supplier, or manufacturing process changes, and to maintain test reports no older than 1-2 years for each packaging SKU.
What is the difference between TPPA and EU packaging regulations?
The EU Packaging and Packaging Waste Regulation (PPWR) covers a broader scope — including recyclability, recycled content, and reduction targets — in addition to heavy metal restrictions. The EU has also maintained a 100 ppm aggregate limit for lead, cadmium, mercury, and hexavalent chromium in packaging since the original Packaging Directive (94/62/EC). The testing methods and documentation expectations differ between the two regimes.
Last updated: July 19, 2026