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.