Food Packaging and Cookware Regulation Act (AB 1200): New Disclosure Obligations Triggered by the Addition of Microplastics to the Candidate Chemicals List
ENFORCEMENT TIMELINE
Phased application in 2023/2024; microplastics addition takes effect October 1, 2026
Overview
AB 1200 (enacted 2021) prohibits intentionally added PFAS in plant-fiber-based food packaging, effective January 1, 2023, and imposes disclosure and labeling requirements on cookware manufacturers for any substance appearing on California's Candidate Chemicals list. Effective January 1, 2024, cookware manufacturers were also required to display the names of relevant chemicals directly on the physical product label, along with a bilingual (English/Spanish) advisory statement.
On June 18, 2026, California's Department of Toxic Substances Control (DTSC) added microplastics to the Candidate Chemicals list, with an effective date of October 1, 2026. Because AB 1200's disclosure and labeling obligations automatically extend to any substance newly added to the Candidate Chemicals list, this addition automatically expands the scope of cookware subject to disclosure requirements. Cookware manufacturers that contain or generate microplastics must determine, by October 1, 2026, whether disclosure obligations apply to their products. DTSC's 2024–2026 Priority Product Work Plan already includes preliminary research into product categories that contain or generate microplastics—including plastic packaging, synthetic textiles, tires, and paints and coatings—raising the possibility that the scope of regulation could eventually expand beyond AB 1200 into the broader Safer Consumer Products (SCP) program's priority-product designation process.
Enforcement Timeline
2021: AB 1200 is enacted
January 1, 2023: Prohibition on intentionally added PFAS in plant-fiber food packaging takes effect
January 1, 2024: Physical label disclosure and bilingual advisory statement requirements for cookware take effect
June 18, 2026: DTSC adds microplastics to the Candidate Chemicals list
October 1, 2026: Effective date of the microplastics listing, triggering automatic disclosure obligations for affected cookware
Business Impact
Cookware manufacturers and brand owners must assess, ahead of the October 1, 2026 effective date, whether their products contain or generate microplastics in a manner triggering AB 1200's automatic disclosure and labeling requirements, given that the Candidate Chemicals mechanism operates without requiring a separate rulemaking specific to each newly listed substance. Companies should also monitor DTSC's ongoing Priority Product Work Plan research into microplastics-containing product categories more broadly, as this signals potential future expansion of regulatory scope beyond cookware into other product types under the SCP program.