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California USA Signs AB-1200 to Require Information for Cookware

10 Oct 2022
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Food Contact Materials (FCM) are regulated in the USA by Title 21 of the Code of Federal Regulations (CFR). Stakeholders should also be aware of local prescriptions on FCM, including state specific requirements on various chemicals in FCM.

Assembly Bill 1200 (AB-1200), was signed into California’s law in October 2021. One part of the policy restricts PFAS that is either intentionally added or >100ppm (as total organic fluorine) in plant-based food packaging. The other part of the policy requires disclosure when any chemicals on the “Designated List” is intentionally added to the handle or food-contacting surface of any cookware, which would become the disclosure rule with broadest coverage of chemicals in California.

A variety of food-contacting articles would need to be assured that none of the 2000+ designated chemicals were intentionally added, or that relevant usage information is properly disclosed to consumer in accordance with the policy.

The Designated List refers to the Candidate Chemical List adopted by the Department of Toxic Substances Control (DTSC), which is in turn referencing to other authoritative lists of chemicals with specific hazards, including:

  1. Endocrine disrupting (ED) or persistent, bio-accumulative and toxic (PBT) chemicals under the EU’s Substance of Very High Concern (SVHC);
  2. California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Prop 65); and
  3. Other 21 lists of chemicals from different authorities or organizations

The published list currently contains more than 2000 chemicals and is subjected to updates over time.

This new chemical disclosure requirement applies to durable houseware items that are used in homes and restaurants to prepare, dispense, or store food, foodstuffs, or beverages. Items like pots, pans, skillets, grills, baking sheets, baking molds, trays, bowls, and cooking utensils are included. 

According to the policy, disclosure shall be in form of website posting from 1 January 2023, and in form of bilingual product label with QR code from 1 January 2024.

To help manufacturers cope with the long and complex list of chemicals that requires disclosure, SGS provides a comprehensive Ingredient Review for Formulation to assist in establishment in required data, formulation review against the designated list, and a summarized review report with tailormade suggested actions.

At SGS we carry out food contact materials testing to ensure that your products comply with Federal & State legislations in the US market.

For more information on this service, please contact our Customer Service team.

To obtain a copy in PDF, please click here.

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