Packaging
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
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Heavy metals (IEEE 4.8.1.1 and NSF 8.1.1)
Separable/markings (IEEE 4.8.2.1 & 4.8.2.3 and NSF 8.1.2)
Chlorine (IEEE 4.8.1.2 and NSF 8.1.4)
NSF 426
8.1.1 Elimination of substances of concern in product packaging
(prerequisite)
Product packaging shall not contain lead, mercury, cadmium or
hexavalent chromium above a total of 100 ppm for the four metals
combined in any packaging component, in accordance with the
European Union Packaging Directive and the Model Toxics in Packaging
Legislation.
IEEE 1680.4
4.8.1.1 Required—Elimination of added heavy metals in packaging
Product criterion: Heavy metals— lead, cadmium, mercury, and
hexavalent chromium—shall not be added to any package or packaging
component. For incidental presence, the sum of the combined
concentrations of lead, cadmium, mercury, and hexavalent chromium
present in any packaging component shall not exceed 100 ppm by weight.
Applies to: Packaging of products that are declared to conform to this
standard. Pallets are excluded.
Verification requirements: a and (b or c)
Declaration from manufacturer
And either
b) Supplier letter for each packaging component or the associated
base materials, that certifies:
1) The specified heavy metals have not been added to any
package or packaging component;
and
2) The sum of the combined concentration of the four metals
present in any packaging component does not exceed 100
ppm by weight.
a)
or
Documentation of a conformance assurance system that
demonstrate conformity to this criterion through effective control
of the supply chain.
References and details: Model Toxics in Packaging legislation [B17], which
is available online through the Toxics in Packaging Clearinghouse
http://www.toxicsinpackaging.org/, the European Parliament and Council
Directive 94/62/EC and California Health and safety Code Section
25214.11-25214.26. Analytical testing is not required for verification to
this criterion. However, if testing is undertaken, ensure that appropriate
test methods are used. For example, energy dispersive x-ray fluorescence
spectrometry can be used with limitations to quantitatively determine the
amount of heavy metals (lead, cadmium, mercury, and total chromium) in
polymeric materials by following ASTM F 2617-08 [B2]. This method does
not determine hexavalent chromium. Materials that exceed 100 ppm
chromium with this method should be further analyzed using destructive
wet testing methods. Laboratory analysis for total metals in polymeric and
other materials can be performed using procedures such as EPA SW-846
Method 3052 [B22] and IEC 62321:2008 [B9].
c)
Key Differences:

Minor differences only
o Exclusions of pallets.
o Reference to CA toxics in packaging codes
o Verification requirements
Proposed Resolution:


Use IEEE 1680.4 criterion in JTG criterion format
For consistency with referenced laws
o Add “intentionally” before “added”
o Keep pallet exclusion; add “for purposes of this standard”.
Rationale: 1) So pallets are not subject to verification; and 2) Exclusion might mislead manufacturer to think pallets are not subject

to laws.
o Under verification requirement b) delete “or the associated base materials”
Rationale: The definition of “packaging components” in the definitions is consistent with The Model Toxic in Packaging Law and CA
code. These laws require conformance of all packaging components, which includes base material, inks, etc. “Packaging components
or the associated base materials” is misleading as it implies that some packaging components do not require supplier letters.”
Keep CA Code citation
Rationale: 19 US states have toxics in packaging legislation, including CA, based on the Model Legislation. The CA Code is consistent with the
Model Legislation and other states, but does provide some additional details not found elsewhere.
Proposed Criterion Language (with modifications to 1680.4 criterion highlighted)
Required—Elimination of added heavy metals in packaging
Heavy metals— lead, cadmium, mercury, and hexavalent chromium—shall not be intentionally added to any package or packaging
component. For incidental presence, the sum of the combined concentrations of lead, cadmium, mercury, and hexavalent chromium present
in any packaging component shall not exceed 100 ppm by weight.
Pallets are excluded for the purposes of this standard.
Verification requirements:
a) Declaration from manufacturer
And either b) or c)
b) Supplier letter for each packaging component or the associated base materials, that certifies:
The specified heavy metals have not been intentionally added to any package or packaging component;
and
The sum of the combined concentration of the four metals present in any packaging component does not exceed 100 ppm by weight.
or
c) Documentation of a conformance assurance system that demonstrate conformity to this criterion through effective control of the supply
chain.
References and details: Model Toxics in Packaging legislation [B17], which is available online through the Toxics in Packaging Clearinghouse
http://www.toxicsinpackaging.org/, the European Parliament and Council Directive 94/62/EC and California Health and safety Code Section
25214.11-25214.26. Analytical testing is not required for verification to this criterion. However, if testing is undertaken, ensure that
appropriate test methods are used. For example, energy dispersive x-ray fluorescence spectrometry can be used with limitations to
quantitatively determine the amount of heavy metals (lead, cadmium, mercury, and total chromium) in polymeric materials by following
ASTM F 2617-08 [B2]. This method does not determine hexavalent chromium. Materials that exceed 100 ppm chromium with this method
should be further analyzed using destructive wet testing methods. Laboratory analysis for total metals in polymeric and other materials can
be performed using procedures such as EPA SW-846 Method 3052 [B22] and IEC 62321:2008 [B9].
8.1.2
Enhancing recyclability of packaging materials (prerequisite)
4.8.2.1 Required—Separable packaging materials
Product criterion: All dissimilar packaging materials shall be separable
without the use of tools (e.g., foam shall not be permanently adhered to
 All non-reusable packaging components ≥25 g shall be separable any other type of packaging material).
by material type, including by plastic material type specified in the
bullet below, without the use of tools, with the exception of labels Exceptions include the following:
a) Plastic bags (or wrap) affixed with labels
affixed to plastics bags or wraps, staples, and nails in pallets.
b) Pallets or pallet assemblies that are part of the primary package.
 All plastics ≥ 25 g shall be clearly marked with material type in
c) Tape, glue, or staples used to construct or close a fiber-based
accordance with ISO 11469/1043, ASTM D7611/D7611M, or DIN1,
container.
with the exception of plastic films.
d) Plastic bags over expanding foam
e) Stretch wrap
f)
Reusable packaging components (packaging components designed
for reuse)
Product packaging shall meet the following requirements:
1
DIN 6120-1 - Marking of packaging and packaging materials for recycling purposes - Plastics packaging and packaging materials - Part 1:
Graphical symbols (http://www.en-standard.eu)
g)
h)
Top sheet adhered to cardboard or paperboard
Individual components less than 25 grams consisting of dissimilar
materials
Applies to: Packaging of products that are declared to conform to this
standard.
Verification requirements:
a)
b)
Declaration from manufacturer
Documentation from manufacturer
 Manufacturer’s packaging part or assembly drawing
4.8.2.3 Required—Plastics marked in packaging materials
Product criterion: All plastic packaging material shall be marked or
embossed by material type per ISO 11469, ISO 1043, SPI resin
identification code, DIN, or country specific code.
The following individual packaging components are excluded:
a) Plastic packaging weighing less than 25g or with a surface area less
than 50 cm2
b) Plastic protective films and stretch wrap
c) Expanded polyurethane
d) Plastic packaging when marking is not possible due to the shape
e) Tape, labels, strapping
For products with packaging that does not contain any plastics,
manufacturer may declare “Not applicable” for this criterion.
Applies to: Packaging of products that are declared to conform to this
standard.
Verification requirements:
a)
b)
Declaration from manufacturer
Photographs, physical evidence, or engineering specifications of the
plastic components
References and details: ISO 11469 referring ISO 1043, SPI resin
identification code, DIN, or country specific code.
Key Differences:

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
One vs. two criteria required criteria
IEEE criteria include detailed lists of exceptions which appear covered in the language in the NSF criterion
Plastics marking criteria allows declaration of N/A
Verification requirements not included in NSF criterion
Proposed Resolution:


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
Use NSF criterion as base
Clearly delineate 2 parts in criteria and allow declaration to each part to allow N/A if no plastic packaging.
Add verification requirements
Change SPI to ASTM
Add IEEE exceptions, as needed
o Added plastic protective film, stretch wrap and strapping
o Expanded polyurethane – e.g., corner brackets; specialized pallet assemblies
o Plastic bag over expanded foam (reactive foam in a bag to form to box and product; typically used for prototypes
Proposed Criterion Resolution
Required - Enhancing recyclability of packaging materials
Product packaging shall meet the following requirements:
a) All non-reusable packaging components ≥25 g shall be separable by material type, including by plastic material type specified in the bullet
below, without the use of tools, with the exception of labels affixed to plastics bags or wraps, staples, nails in pallets, and plastic bags over
expanded foam.
b) All plastics ≥ 25 g shall be clearly marked with material type in accordance with ISO 11469/1043, ASTM D7611/D7611M, or DIN2, with the
exception of plastic protective films, stretch wraps, strapping, and expanded polyurethane.
Each requirement above shall be declared separately. For products with packaging that does not contain any plastics, manufacturer may declare
“Not applicable” for requirement b) in this criterion.
Verification requirements:
a) Declaration from manufacturer
and
b) Documentation from manufacturer:
For requirement a), manufacturer’s packaging part or assembly drawing
For requirement b) photographs or physical evidence of plastic markings.
References and details:
2
DIN 6120-1 - Marking of packaging and packaging materials for recycling purposes - Plastics packaging and packaging materials - Part 1:
Graphical symbols (http://www.en-standard.eu)
8.1.4 Elimination of chlorine in processing packaging materials 4.8.1.2 Required—Elimination of elemental chlorine as a bleaching
agent in paper-based packaging material
(prerequisite)
Manufacturer shall document with a supplier letter that any fiber-based
materials used in packaging was not bleached with chlorine compounds.
This requirement applies to the bleaching of fiber-based materials
(including recycled fiber) and their fabrication into packaging for server
products declared to conform to this standard, and not to prior uses of
the fiber.
Product criterion: Manufacturer shall state in the manufacturer’s
environmental packaging requirement that elemental chlorine shall not
be used as a bleaching agent to bleach virgin or recovered content fibers
used in paper-based product packaging.
Product packaging that is made Elemental Chlorine Free (ECF), Total
Chlorine Free (TCF), or Processed Chlorine Free (PCF) meets the
requirements of this criterion.
Additionally, recycled content that may have been previously bleached
with chlorine or chlorine derivatives meets the requirements of this
criterion.
Applies to: Packaging of products that are declared to conform to this
standard
Verification requirements:
a)
Declaration from manufacturer
b)
Copy of manufacturer’s environmental packaging requirement as
provided to packaging supplier
References and details: None.
Key Differences:

Elimination of chlorine compounds (NSF) vs elemental chlorine (IEEE)
Proposed Resolution:





Choose one or the other for required criterion
Include 2 criteria – one required with elemental chlorine that establishes a minimum requirement, and an optional for chlorine compounds
that establishes a leadership criterion (see NSF research document)
Include only 1 criterion on chlorine compounds (rationale: industry mostly meets elemental requirement now; provides leadership incentive)
With any of the above, change title to read “Restriction on in Use of….”
Add verification requirements to NSF criterion
Proposed Criteria Language (2 criteria)
Required—Restriction on the use of elemental chlorine as a bleaching agent in paper-based packaging material
Product criterion: Manufacturer shall state in the manufacturer’s environmental packaging requirement that elemental chlorine shall not be
used as a bleaching agent to bleach virgin or recovered content fibers used in paper-based product packaging.
Product packaging that is made Elemental Chlorine Free (ECF), Total Chlorine Free (TCF), or Processed Chlorine Free (PCF) meets the
requirements of this criterion.
Additionally, recycled content that may have been previously bleached with chlorine or chlorine derivatives meets the requirements of this
criterion.
Applies to: Packaging of products that are declared to conform to this standard
Verification requirements:
a) Declaration from manufacturer
b) Copy of manufacturer’s environmental packaging requirement as provided to packaging supplier
References and details: None.
Optional – Restriction on the use of chlorine in processing packaging materials
Manufacturer shall document with a supplier letter that any fiber-based materials used in packaging was not bleached with chlorine compounds.
This requirement applies to the bleaching of fiber-based materials (including recycled fiber) and their fabrication into packaging for server
products declared to conform to this standard, and not to prior uses of the fiber.
Verification requirements:
a) Declaration from manufacturer
b) Supplier letter
References and details: None.
NSF 426 Definitions
Overlapping Criteria where
Term is Used
3.36 Packaging: See packaging system.
Packaging: All NSF/IEEE
3.37 Packaging component 3: Any individual assembled part
of a package such as, but not limited to, (a) any interior or
exterior blocking, bracing, cushioning, weatherproofing,
exterior strapping, coatings, closures, inks, and labels; (b) tinplated steel that meets American Society for Testing and
Materials (ASTM) A-623; (c) electro-galvanized coated steel
and hot-dipped coated galvanized steel that meets ASTM A-525
and A-879.
3.38 Packaging optimization4: Process for the achievement of
minimum adequate weight or volume (source reduction) for
meeting the necessary requirements of primary or secondary or
transport packaging, when performance and user/consumer
acceptability remain unchanged or adequate, thereby reducing
the impact on the environment.
Packaging: NSF 8.1.1 /IEEE 4.8.1
4.8.1.1
3
4
Model Toxics in Packaging Legislation (www.toxicsinpackaging.org)
ISO 18602:2013(E)
IEEE-NSF JTG Definition
3.39 Packaging system5: Complete set of packaging for a
packaged good, encompassing one or more of the following that
are applicable (depending on the packaged goods): primary
packaging, secondary packaging, tertiary (i.e., distribution or
transport) packaging.
Packaging: All NSF/IEEE (since
“packaging” referenced)
NOTE – For the purposes of this Standard, unless otherwise noted in a
criterion, product packaging refers to the primary (sales or unit
packaging) and secondary (holding two or more primary packages)
packing of the product declared to the standard.
3.41 Plastic6: A material that contains, as an essential
ingredient, one or more organic polymeric substances of large
molecular weight, is solid in its finished state, and, at some
stage in its manufacture or processing into finished articles, can
be shaped by flow.
Materials: NSF 7.1.1, 7.1.2, 7.2.1/
IEEE 4.2.1.1, 4.2.1.2, 4.2.1.3
3.42
Polymer:
Substance consisting of molecules
characterized by the repetition (neglecting ends, branch
junctions, other minor irregularities) of one or more types of
monomeric units.
3.43 Postconsumer recycled material7: Material generated by
households or by commercial, industrial and institutional
facilities in their role as end-users of the product, which can no
longer be used for its intended purpose. This includes returns of
material from the distribution chain.
Used in definition of plastic
Packaging: NSF 8.1.2/IEEE
4.8.2.1, 4.8.2.3
Materials: NSF 7.1.1, 7.1.2, 7.2.1/
IEEE 4.2.1.1, 4.2.1.2, 4.2.1.3
(Note: IEEE uses PCR plastic, not
material)
NOTE – This definition applies to materials such as plastic, fiber,
metal, etc.
3.55 Recycled content8: Proportion, by weight, of recycled
material in a product or packaging. Only pre-consumer and
post-consumer materials shall be considered as recycled content.
5
ISO 18602: 2013(E)
6
ASTM D883-12 Standard Terminology Relating to Plastics
7
ISO 14021, Environmental Labels & Declarations
ISO 14021, Environmental Labels & Declarations
8
Materials: NSF/IEEE
Packaging: NSF
content fiber)
8.1.3
(PCR