CPE Regulatory Compliance & Sustainability 5 — Questions and Answers
Question 1: The Science Based Targets initiative (SBTi) FLAG guidance specifically relevant to packaging companies using agricultural fiber requires that land-use emissions targets align with keeping global warming to:
- 2.0°C above pre-industrial levels
- 1.5°C above pre-industrial levels (Correct answer)
- Below 1.0°C above pre-industrial levels
- Net-zero by 2050 without interim temperature targets
Correct answer: 1.5°C above pre-industrial levels
SBTi's FLAG (Forests, Land, and Agriculture) guidance requires companies to set science-based targets aligned with the 1.5°C pathway, including land-use change emissions.
Question 2: Under the US Toxic Substances Control Act (TSCA) Section 6(h), EPA issued risk management rules restricting certain chemicals relevant to packaging manufacturing. Which chemical class was the subject of the first TSCA Section 6 rules finalized after the 2016 Lautenberg Act reform?
- Phthalates in flexible PVC packaging
- Methylene chloride and NMP in paint strippers used in facilities (Correct answer)
- Per- and polyfluoroalkyl substances (PFAS) in food contact paper
- Styrene in expanded polystyrene packaging
Correct answer: Methylene chloride and NMP in paint strippers used in facilities
The first TSCA Section 6 final rules after Lautenberg addressed methylene chloride and NMP in paint and coating removal products, affecting facilities including packaging manufacturers.
Question 3: A sustainability manager is comparing the environmental impact of reusable vs. single-use packaging systems. What metric is used to determine the 'break-even point' where reusable packaging becomes environmentally preferable?
- Number of uses (trip count) required for reusable to offset its higher production impact (Correct answer)
- Percentage of recycled content in single-use option
- Carbon intensity of the manufacturing site
- End-market value of the recovered material
Correct answer: Number of uses (trip count) required for reusable to offset its higher production impact
The break-even trip count is the number of reuse cycles needed for the reusable system's total LCA impact to become lower than the cumulative impact of equivalent single-use packages.
Question 4: The Packaging Covenant approach used in Australia (APCO) and Netherlands is a regulatory model characterized by:
- Mandatory government-set recycled content minimums enforced through fines
- Voluntary industry agreements with government-set sustainability targets and public accountability reporting (Correct answer)
- Deposit-return schemes funded entirely by consumer levies
- Carbon taxes applied per kilogram of non-recyclable packaging sold
Correct answer: Voluntary industry agreements with government-set sustainability targets and public accountability reporting
Packaging covenants are voluntary agreements between industry and government where companies commit to sustainability targets and report publicly on progress, avoiding prescriptive mandates.
Question 5: Under 21 CFR 177, which criterion allows a recycled plastic to be used as a food contact material without a new FDA food additive petition when the recycling process has been evaluated?
- The recycled resin passes a 30-day migration test at 70°F
- The process is covered by an FDA Letter of Non-Objection (LNO) confirming adequate decontamination (Correct answer)
- The material is GRAS (Generally Recognized As Safe) by consensus
- The recycler holds ISO 22000 food safety certification
Correct answer: The process is covered by an FDA Letter of Non-Objection (LNO) confirming adequate decontamination
FDA issues Letters of Non-Objection (LNOs) for specific recycling processes, confirming that the process adequately reduces potential contaminants so recycled resin is safe for food contact use.
Question 6: The Cradle to Cradle (C2C) certification system evaluates packaging across five quality categories. Which category specifically addresses the safety of materials to humans and the environment?
- Material Health (Correct answer)
- Material Reutilization
- Renewable Energy & Carbon Management
- Water Stewardship
Correct answer: Material Health
C2C's Material Health category assesses the safety of all intentionally used chemicals in a product to human health and environmental health using a rigorous chemical assessment methodology.
Question 7: The SEC's climate disclosure rules (finalized 2024) require public companies, including packaging manufacturers, to disclose Scope 3 emissions only if:
- Scope 3 emissions exceed 40% of total company emissions
- They are material or the company has set a Scope 3 reduction target (Correct answer)
- Annual revenue exceeds $1 billion
- They operate manufacturing facilities in more than one country
Correct answer: They are material or the company has set a Scope 3 reduction target
Under the SEC's climate rules, Scope 3 disclosure is required only when Scope 3 emissions are material to investors or the company has included Scope 3 in its publicly stated climate targets.
CPE Regulatory Compliance & Sustainability 5
The Science Based Targets initiative (SBTi) FLAG guidance specifically relevant to packaging companies using agricultural fiber requires that land-use emissions targets align with keeping global warming to: