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US California Toxic Substances Regulation for Food Packaging and Cookware (AB 1200)

ENFORCEMENT TIMELINE

Phased implementation beginning January 1, 2023

Enforcement: Phased implementation beginning January 1, 2023

Overview

California's AB 1200 bans intentionally added PFAS in paper-based food-contact packaging and requires disclosure labeling—on the product itself and on the company website—when cookware (frying pans, pots, etc.) contains designated chemicals on the food-contact surface, such as Proposition 65-listed substances or PFAS.

Enforcement Timeline

- October 2021: Signed into law by the governor

- January 1, 2023: Ban on sale of plant-fiber-based food packaging containing intentionally added PFAS takes effect

- January 1, 2023: Online disclosure obligation for designated chemicals in cookware takes effect

- January 1, 2024: Disclosure label requirement on cookware itself and its outer packaging takes effect

Related Regulations / Topics

Food Packaging and Cookware Regulation Act (AB 1200): New Disclosure Obligations Triggered by the Addition of Microplastics to the Candidate Chemicals List

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.

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Business Impact

Food packaging material manufacturers and cookware manufacturers/importers must fully eliminate PFAS from food packaging and disclose coating ingredients used in cookware. Non-compliant products are subject to sale suspension and civil penalties.

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Official Sources & Reference Links