These updates were provided to PPAI’s Product Responsibility Action Group during its July meeting by Karolyn Helda, QIMA, and Rick Brenner, Product Safety Advisors:

U.S. Federal Legislation

A group of Democrats in the House introduced the “No Toxic Chemicals in Food Packaging Act of 2026” on June 9. This bill has a low likelihood of passage but is worth monitoring.

  • Targets hazardous chemicals in food contact products and packaging under the Federal Food, Drug and Cosmetic Act (FD&C Act).
  • Restricted substances: phthalates, PFAS, bisphenols, formaldehyde, styrene polymers, BHA, acrylamide, benzene and more.
  • Residual manufacturing amounts not expressly addressed.
  • Preserves stricter state-level rules (e.g. California).
  • If passed, it would take effect two years after enactment.


U.S. Federal Agency Updates

The Federal Trade Commission issued “Made in USA” warning letters on July 6 targeting seven companies. Companies can be subject to stiff penalties if they use an unqualified “Made in USA” claim for a product that is not “all or virtually all” made in the United States, and recent executive orders increased FTC oversight signal that this will continue to be an enforcement priority.

RELATED: Understanding ‘Made In The USA’ Labeling Rules

Required PFAS reporting under the Toxic Substances Control Act has been delayed multiple times by the Environmental Protection Agency, and a final rule is expected to be published by the end of July, although it is unclear whether “published” means in the Federal Register or submission to the Office of Management and Budget.

ICYMI: Federal PFAS Reporting Period Postponed Again

U.S. States – California

California’s Department of Toxic Substances Control has added microplastics to its to its Safer Consumer Products Candidate Chemicals List.

  • Defined as plastic particles under 5mm, including fragmented plastics released during use.
  • Listing does not impose immediate product restrictions or reporting obligations.
  • Next step: Identify priority products; single-use plastics likely first focus.
  • Textile shedding appears to be deprioritized for now.


Separately, OEHHA (the California health department) announced a July 30 pre-rulemaking workshop on Prop 65 amendments, with draft regulatory language expected to be published before the workshop. (Register here.)

LEARN MORE: Attend the PPAI Responsibility Summit, September 14-16 in Denver.

European Ceramic Regulations: Benelux

Luxembourg and the Netherlands revised their food contact ceramic limits, effective May 29:

  • Harmonizes requirements across the Benelux region (Belgium, Netherlands, Luxembourg) with stricter migration limits for lead and cadmium.
  • Requires compliance documentation aligned with EU standards (EU Directive 84/500/EEC).
  • Netherlands allows sell-through period for legacy product until December 1, 2026.
  • No sell-through period in Luxembourg – all product must comply immediately.


Australia: Industrial Chemicals

Australia has amended its Industrial Chemicals Environmental Management Register with new restrictions on PFAS, short-chain phthalates, lead, parabens and more. New schedule entries impact chemicals commonly used in plastics, surfactants, flame retardants, consumer products and coatings.

Key compliance dates:

  • In force: June 19, 2026
  • Most new chemical listings effective: January 1, 2027
  • Certain PFAS-related listings effective: July 1, 2027


Product Recalls

CPSC recalls year-to-date top 300, a 45% increase year-over-year. Button-cell batteries dominate those recalls. (View CPSC’s Button Cell and Coin Battery Business Guidance.)

  • Industry-adjacent recalls include an Arctic Zone cooler, insulated food bowl, light-up novelties (batteries) and a power bank.


California Prop 65 Notices

More than 2,800 Prop 65 notices of violation have been issued YTD, up 39% YOY. Decorated ceramics and glassware dominated the NOVs in June, with fresh 60-day notices for lead/cadmium in mugs, plates and jars with printed designs, as well as an Owala water bottle sold in retail. Housewares/Tools (14) and Drinkware (13) together account for more than half of the past month’s 47 notices.

New Regulatory Roundup Tool Online

NEW: Visit the new PRAG Update page for detailed information on the latest regulatory developments, including CPSC recalls and other actions, Prop 65 notices, legislative news and much more.

CPSC eFiling

CPSC eFiling – posting required certificate data electronically for a wide range of imported products – went live on July 8, with mixed reports. Challenges shared by PRAG members include:

  • Customs brokers are carrying the heaviest lift.
  • The U.S. Harmonized Tariff Schedule code list is not comprehensive, causing filing disputes with brokers (eFiling applies only to CPSC-regulated products).
  • Freight carriers have provided conflicting guidance on containers with a mix of goods that do or don’t need certificates.
  • Importer-of-record coordination is a known gap.


Members who participated in the voluntary eFiling beta testing group recommend that all importers know what does and does not require eFiling and communicate clearly with brokers on each invoice.

LEARN MORE: CPSC eFiling Starts July 8

China Updates Standard for Portable Power Banks

China has updated its Triple C/3C/CCC with a new mandatory standard for power banks, lithium-ion batteries for power banks and battery packs (GB 47372-2026: Safety Technical Specification for PowerBanks) and provided new implementation rules (CNCA-C09-02:2026). All relevant products must be in compliance with these new regulations by April 1, 2027.

  • Relevant for any members in the tech/power bank category.
  • Differs from UL 1642; likely stricter.
  • Chinese factories selling domestically must change manufacturing processes to comply.
  • Watch whether UL attempts to harmonize with 3C.
  • Each product will need its own unique code so consumers can check key information, including the manufacturer.


PPAI Responsibility Summit

Early-bird pricing for PPAI’s Responsibility Summit – September 14-16 in Denver – is available through July 30. Program details are being finalized, and details will be added to the event page in the coming weeks.

Regulatory sessions will address core requirements including product labeling and chemicals of concern, as well as key challenges such as packaging EPR, PFAS compliance and eFiling. Content will also include sustainability technology and the ethical use of AI. Attendees will leave with a clearer understanding of requirements and actionable approaches to manage risk and support decision-making in a complex and evolving landscape.