CONEG stands for the Coalition of Northeastern Governors comprised of the following member states: Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island and Vermont. The coalition was the driving force in Toxics in Packaging Legislation when it created the model legislation many states adopt today. This served as a template for different states to institute regulations of their own using the same language. Though each state modifies the regulation to a certain extent, the spirit of the regulation remains close to the aims identified by the Model Legislation. The Regulation The goal of this legislation is to reduce the sum concentration levels of four incidentally introduced heavy metals, namely lead, mercury, cadmium and hexavalent chromium present in any package or packaging component to not exceed 100 parts per million by weight. It is important to note that the 100 ppm limit applies to the combined weight of all the above metals and NOT individually. Definitions under CONEG It defines a Package as “any container, produced either domestically or in a foreign country, providing a means of marketing, protecting or handling a product and shall include a unity package, an intermediate package or a shipping container…This includes unsealed receptacles as carrying cases, crates, cups, pails, rigid foil and other trays, wrappers and wrapping films, bags and tubs.” It defines a Packaging Component as “any individual assembled part of a package which is produced either domestically or in a foreign country, such as but not limited to, any interior or exterior blocking, bracing, cushioning, weatherproofing, exterior strapping, coatings, closures, inks and labels”. Please note that again, each state may issue addendums to definitions under the Model Legislation. For instance in California, the definition of Packaging Component includes “dyes, pigments, adhesives, stabilizers and any other additives”. Who must comply? Toxics in Packaging Legislation requires compliance from the following parties: Manufacturers and/or Suppliers of Packaging and Packaging Components Product Manufacturers or Distributors who use Packaging How to Comply? Under the Model Legislation, manufacturers and suppliers of packaging and packaging components must submit a Certificate of Compliance stating that the package is in compliance with the requirements of the law to the purchaser of these items.
CONEG Toxics in Packaging – PVC Tech Corp Compliance Summary
The certificate must be: 1. Based on verifiable evidence that no intentional addition of the four metals have occurred. 2. Signed by an authorized official of the manufacturing or supplying company. 3. Must be kept on file for as long as the packaging is in use. 4. Must contain any relevant amendments or modifications reflecting any reformulations to the packaging or
packaging component. 5. Must be available to any member of the public who requests the certificate.
Individual states may modify compliance requirements as per their individual statutes, it is important to check with the state concerned when attempting to comply with state regulations. Is CONEG the same as the EU Packaging Directive, and can I use CONEG certification to comply in the EU? Both CONEG and the EU impose a 100 ppm limit to the combined sum total content of the four heavy metals: lead, mercury, cadmium and hexavalent chromium. There is a difference in the language of each regulation, where CONEG limits the “incidental” presence of the substances versus the EU Packaging Directive which makes no distinction between intentional and incidental content of the very same. The applicable laboratory test however, will apply to both as it will measure total content of the combined four substances in the packaging or packaging component. In so far as testing results are concerned, this would satisfy both regulations and your manufacturer can issue certification based on this. If you receive certification with no testing, both regulations should be referenced to keep your documentation precise. Are CONEG and the RoHS related, and can I use certifications for these interchangeably? No, certifications for CONEG and/or the EU Packaging Directive and the RoHS are not interchangeable, though this is a common misperception due to some overlap in the covered substances. The differences are shown below:
CONEG – EU Packaging Directive RoHS • Imposes a total content limit on the combined sum of four
heavy metals. • Applies to Packaging and Packaging Components.
• Imposes an individual limit to EACH of the four heavy metals, with a specifically stricter limit on cadmium.
• Includes restrictions on flame retardant substances PBB & PBDE.
• Applies to Electric and Electronic Equipment.
I manufacture packaging that will hold a child’s article and/or toy -‐ will I only need to comply with CONEG or do I need to worry about the CPSIA as well? Your obligations under each regulation are clarified by how your packaging is used with the child’s product or article. If your packaging is discarded after use, has no play value, is not used in conjunction with the child’s product for the duration of its life span whether as part of its use or as a vessel, then your packaging would be considered for general use and will only need to meet the requirements of CONEG for the US or the EU Packaging Directive if being sent to Europe.
CONEG Toxics in Packaging – PVC Tech Corp Compliance Summary
However, if the opposite is true, then your packaging would be considered part of the child’s product and the CPSIA requirement would also apply. Here are examples:
a. Your packaging is a thermoformed package holding an action figure that is discarded after use – the CPSIA would not apply.
b. Your packaging is a flexible pouch that holds a doll, its accessories such as a doll comb, doll jewelry etc. and is designed to be used together for play – the CPSIA would apply.
PVC Tech Corp and Toxics in Packaging PVC Tech Corp offers a variety of rigid and flexible materials certified to CONEG and the EU Packaging Directive. While not all of our stock flexible substrates meet CONEG, we are able to produce CONEG compliant versions upon request. All our certifications are traceable to our manufacturers who provide compliance documents as requested.
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