If you sell packaged products in the U.S., you’ve probably run into a compliance form asking you to certify that your packaging is free of “CONEG metals.” That requirement traces back to a single piece of model legislation from 1989 that still shapes packaging decisions today — and getting it wrong can mean rejected purchase orders, retailer delistings, or state enforcement action.
This guide breaks down what the CONEG heavy metals packaging law actually requires, which states enforce it, how the 100 ppm limit works, and the practical steps a brand owner needs to take to stay compliant — including how to get a proper Certificate of Compliance from your suppliers.
Quick Answer
The CONEG heavy metals packaging law is model legislation, originally developed in 1989 by the Coalition of Northeastern Governors (CONEG) and now maintained by the Toxics in Packaging Clearinghouse (TPCH), that bans intentionally adding lead, cadmium, mercury, or hexavalent chromium to packaging and caps the incidental (unintentional) combined total of those four metals at 100 parts per million by weight. It has been adopted, with some variation, by roughly 19 U.S. states, and compliance is typically demonstrated with a signed Certificate of Compliance from each packaging manufacturer or supplier.
What the Law Actually Requires
The rule has two parts. First, no package or packaging component — boxes, labels, inks, closures, inner liners, pallets, and similar materials — may have lead, cadmium, mercury, or hexavalent chromium intentionally introduced during manufacturing, as an ingredient or additive of any kind. Second, because trace amounts of these metals can turn up unintentionally (often from recycled feedstock or shared manufacturing equipment), the law allows an incidental presence, but the combined concentration of all four metals in any single packaging component cannot exceed 100 ppm.
The requirement applies broadly to anyone in the packaging supply chain who takes title to the packaging for sale, including manufacturers, brand owners, distributors, and retailers — not just the company that molds or prints the material. That’s why a Certificate of Compliance follows the packaging down the supply chain: each party needs its own documentation to pass along to the next.
A handful of exemptions exist without requiring a formal petition, most notably packaging made from recycled content (states generally recognize that recycled material can carry incidental metal residue, with most states applying the 100 ppm threshold and New Hampshire allowing up to 200 ppm) and packaging manufactured before a state’s law took effect. Other exemptions require a formal petition to the relevant state agency with supporting test data.
How to Stay Compliant as a Brand Owner
Start by mapping every packaging component in your supply chain — primary packaging, secondary/shipping packaging, labels, inks, adhesives, and any promotional inserts — since the law applies at the component level, not just the finished package as a whole. For each component, request a signed Certificate of Compliance from the manufacturer or supplier stating that none of the four regulated metals was intentionally added and that incidental levels stay under 100 ppm. Keep signed certificates on file for as long as that packaging remains in use; several states allow public and regulator requests for this documentation.
If a certificate can’t be produced, or if a component uses recycled content, pigments, or metallic inks (common sources of incidental heavy metals), consider third-party lab testing. EPA Method 3052 (full digestion) is the standard confirmatory method; XRF screening is a fast, non-destructive first pass but should be backed by digestion-based testing if results are borderline. Test each packaging component separately, since the 100 ppm limit applies per component, not as an average across a multi-part package.
Because roughly 19 states have adopted the model law with minor variations (and California and New York enforce their own statutes with additional provisions, including expanded PFAS restrictions in several states), build your compliance program to the strictest applicable state rather than tracking each jurisdiction separately. If you sell nationally, that effectively means complying everywhere.
Tips / Common Mistakes
Don’t assume a supplier’s general “eco-friendly” or RoHS claim covers CONEG compliance — RoHS applies to electronics and uses different thresholds and substances. Ask specifically for a Toxics in Packaging Certificate of Compliance.
Don’t treat the certificate as a one-time formality. Formulation changes, new ink suppliers, or a switch to recycled substrate can all reintroduce risk, so refresh certificates whenever a packaging spec changes.
Don’t overlook secondary and tertiary packaging. Corrugated shippers, pallet wrap, and printed cartons are packaging components under the law and need their own documentation, even though they never reach the end consumer.
Don’t confuse “incidental” with “a little bit is fine.” Any deliberate addition of the four metals — even in a pigment or stabilizer — is an intentional-use violation regardless of the resulting concentration; only unintended trace contamination falls under the 100 ppm allowance.
Explore more: More packaging compliance guides.
CONEG Heavy Metals Packaging Law FAQs
What does CONEG stand for in packaging law?
CONEG stands for the Coalition of Northeastern Governors, whose Source Reduction Council developed the original Model Toxics in Packaging Legislation in 1989. The Toxics in Packaging Clearinghouse (TPCH) now maintains and updates the model.
What is the 100 ppm limit in the heavy metals packaging law?
It’s the maximum combined concentration, by weight, of incidentally present lead, cadmium, mercury, and hexavalent chromium allowed in any single packaging component. Intentional addition of any of these metals is prohibited outright, regardless of concentration.
Do all states enforce the CONEG heavy metals rule?
No. Roughly 19 states have adopted versions of the model legislation, including California, New York, Connecticut, Illinois, Minnesota, and others. Enforcement and minor exemption details vary by state, so brand owners selling nationally typically comply with the strictest applicable requirements.
Who is responsible for providing a Certificate of Compliance?
Packaging manufacturers and suppliers are required to provide a signed Certificate of Compliance to the purchaser of the packaging. Brand owners should collect and retain these certificates for every packaging component they use and be prepared to produce them to state agencies or the public on request.
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Photo by Trnava University on Unsplash.