CPE Regulatory Compliance & Sustainability 3 — Questions and Answers
Question 1: A packaging engineer is designing a pouch with a barrier layer. Under the EU REACH regulation, which action is required if the barrier material contains a Substance of Very High Concern (SVHC) above 0.1% w/w?
- Immediately substitute the substance
- Notify the ECHA and provide safe use information to recipients (Correct answer)
- Apply for a REACH authorization before market placement
- File an exemption with the national authority
Correct answer: Notify the ECHA and provide safe use information to recipients
Articles containing SVHCs above 0.1% w/w must be notified to ECHA and safe use information communicated to recipients upon request; authorization is required only if the SVHC is on the Authorization List.
Question 2: Extended Producer Responsibility (EPR) programs for packaging shift the cost of end-of-life management to:
- Municipal governments
- Waste haulers
- Producers who place packaging on the market (Correct answer)
- Retailers who sell packaged goods
Correct answer: Producers who place packaging on the market
EPR programs make producers financially and/or operationally responsible for collecting and recycling packaging they introduce to the market.
Question 3: When performing a Recyclability Assessment for the How2Recycle label program, what minimum percentage of US households must have access to drop-off or curbside collection for a material to qualify as 'Widely Recyclable'?
- 50%
- 60%
- 80% (Correct answer)
- 95%
Correct answer: 80%
How2Recycle requires that at least 80% of US households have access to recycling collection for a packaging component to earn the 'Widely Recyclable' designation.
Question 4: The Montreal Protocol's Kigali Amendment, which affects packaging operations, primarily targets the phase-down of:
- Chlorofluorocarbons (CFCs) used in blowing agents
- Hydrofluorocarbons (HFCs) used in refrigerant-cooled packaging lines (Correct answer)
- Methyl bromide used in fumigant packaging
- Sulfur hexafluoride used in modified atmosphere packaging
Correct answer: Hydrofluorocarbons (HFCs) used in refrigerant-cooled packaging lines
The Kigali Amendment added HFCs — commonly used in refrigeration and air conditioning in manufacturing plants — to the Montreal Protocol phase-down schedule.
Question 5: In the US, which federal agency has primary jurisdiction over indirect food additives, including packaging materials that may migrate into food?
- EPA
- USDA
- FDA (Correct answer)
- CPSC
Correct answer: FDA
The FDA regulates food contact materials under the Federal Food, Drug, and Cosmetic Act, requiring that packaging substances that may migrate into food be approved as food additives or meet threshold of regulation criteria.
Question 6: The Sustainable Packaging Coalition's COMPASS tool is used to compare packaging designs based on:
- Cost per unit and weight reduction
- Cradle-to-gate environmental metrics from LCA data (Correct answer)
- Recyclability scores and consumer perception
- Carbon offset credits earned per kilogram of material
Correct answer: Cradle-to-gate environmental metrics from LCA data
COMPASS (Comparative Packaging Assessment) quantifies cradle-to-gate environmental metrics—energy, GHGs, water, and solid waste—using LCA methodology to compare packaging alternatives.
Question 7: Under ASTM D6400, which condition must flexible packaging film meet to qualify as 'compostable' for industrial composting claims?
- Disintegrate into particles ≤2mm and biodegrade ≥90% in 180 days under controlled composting conditions (Correct answer)
- Break down completely in home compost within 12 weeks
- Achieve 50% biodegradation in 90 days in a marine environment
- Dissolve in water at ambient temperature within 30 days
Correct answer: Disintegrate into particles ≤2mm and biodegrade ≥90% in 180 days under controlled composting conditions
ASTM D6400 requires disintegration to ≤2mm in 12 weeks and ≥90% biodegradation within 180 days under controlled industrial composting conditions.
CPE Regulatory Compliance & Sustainability 3
A packaging engineer is designing a pouch with a barrier layer.
Under the EU REACH regulation, which action is required if the barrier material contains a Substance of Very High Concern (SVHC) above 0.1% w/w?