EPA PBT Compliance Request

We recently received a request from a customer to sign a form/letter stating that we were compliant with the new EPA regulations on PBT’s in the boxes we manufacture for them. Have you heard of any other box maker that have been asked to sign such documents?

They also reference compliance to RoHS requirements.

Regarding the PBT compliance, probably the best and most efficient thing to do is contact your suppliers and request a reply, in writing, to the questions your customer has asked, and/or a COA (Certificate of Compliance) for both the EPA and RoHS regulations. You may be able to collect this information from their Safety Data Sheets, but make for you have the latest official documents from them, and if possible, make sure they are original documents and not photocopies.

The chemicals referenced in the January 2021 EPS issued rule include Decabromodiphenyl ether (DecaBDE), Phenol, isopropylated phosphate (3:1) – (PIP 3:1), 2,4,6-Tris(tert-butyl)phenol (2,4,6-TTBP), Hexachlorobutadiene (HCBD), and Pentachlorothiophenol (PTCP).

Typically we don’t think you’re going to find the chemicals in the EPA description in the paperboard, inks, or starch adhesives used to make standard corrugated packaging. We don’t know the exact extent of the information your customer is asking for, but if you are shipping product to your customer on plastic pallets, with plastic strapping, or plastic wrapping, you may want to request information from your suppliers of those products as well.

We have had a few discussions on RoHS compliance previously in this blog. In the sidebar under “Search Ask Ralph” type RoHS and hit enter to find these articles.

Do any of our readers and followers have any information or experiences to share on this topic?

— Ralph

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