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Regulatory Information

Here is What You Will Learn

Over the past several years our industry has been inundated with a seemingly endless stream of new or "updated" regulations from around the world. The information that follows has been accumulated from many sources and is correct to the best of our knowledge. The various documents and other write-ups are meant as guidance and should not be construed as legal documents or advice.

In this section you will learn about:

Important Terms

  • PTFE
  • PFOA
  • VOCs
  • APEO
  • Sol-gel “Ceramic” Coatings
  • Globally Harmonized System (GHS)

North America
Food Contact

  • FDA Regulations for traditional nonstick coatings
  • FDA Regulations for sol-gel coatings
  • Health Canada
  • Consumer Product Safety Commission (CPSC)
  • Standard Setting Bodies - NSF & UL

Other Regulations

  • California’s Proposition 65
  • California Safer Consumer Products Regulations
  • Conflict Minerals

Take-Back Regulations

  • United States
  • Canada

Food Contact

  • EU Commission Regulation 1935/2004/EU
  • Council of Europe Framework Resolutions
  • National Legislation
  • Standard Setting Bodies – TÜV (Nord, Rheinland, Süd)

Europe (cont.)
Other Regulations

  • Turkey

Take-Back Regulations

  • RoHS
  • WEEE
  • Norway PoHS
  • Turkey RoHS

South America
Food Contact

  • Mercosur
    • Argentina
    • Brazil
  • Chile
  • Andean Community of Nations (CAN)

Take-Back Regulations

  • Brazil

Food Contact

  • Australia and New Zealand
  • China
  • India
  • Japan
  • South Korea
  • Taiwan
  • ASEAN Countries
  • Eurasian Economic Community

Other Regulations

  • Malaysia CLASS
  • South Korea CCA
  • South Korea REACH (K-REACH)
  • Taiwan Toxic Chemical Control Act

Take-Back Regulations

  • China ACPEIP
  • Japan RoHS
  • South Korea RoHS

Important Terms

PTFE (polytetrafluoroethylene): What most people know as Teflon® (the brand name of DuPont) is the principal ingredient used in coatings for cookware, bakeware and small appliances; PTFE provides the release component to these coatings. PTFE was discovered in 1938 by Roy Plunkett of DuPont and has been used as a component of cookware coatings since the early 1950s. Other fluoropolymers are sometimes used in conjunction with PTFE, including FEP (fluorinated ethylene propylene) and PFA (perfluorinated alkoxy). All these materials are well proven and accepted throughout the world as being safe for use in food-contact applications.

PFOA (perfluorooctonoic acid): Also sometimes referred to as APFO (ammonium perfluorooctanoate) or by the chemical shorthand C-8, PFOA has been used as a process aid in making certain kinds of PTFE resins. Only about 10% of the PTFEs produced use PFOA in the manufacturing process, including the materials historically used in cookware coatings. Through a voluntary initiative between the resin manufacturers and the US EPA, however, PFOA use is being phased out. As a result there are many PFOA-free versions available. The PTFEs used in bakeware materials do not contain PFOA.

Regulatory Agencies in the US and Europe have been studying PFOA exposures in cookware since 1999 and in multiple studies did not find PFOA in cookware. This can be explained using basic chemistry. First, coatings are cured at temperatures above 550 °F/287°C for at least 10 minutes. PFOA sublimes (e.g. transforms from solid directly to a gas) at 266 °F /130 °C and boils at 372 °F /189 °C. This means that when the coating is cured, the PFOA evaporates — just like water and alcohol do when making a reduction for a sauce.

VOCs (Volatile Organic Compounds): These are the solvents that evaporate from coatings when they are applied and cured. Most cookware coatings are waterborne, with the water being evaporated during the cure process. Any solvents that are used are a minor component of the formulae. All coatings have “allowable” amounts of VOCs set by the EPA in the US and by the EU. These regulations are administered by the environmental departments of the various states or member countries. Generally for the US, pigmented materials are allowed 3.5 pounds/gallon (120 grams/liter) of VOCs. Clear coatings have an allowance of 4.3 pounds/gallon (150 grams/liter) of VOCs.

APEO (Alkyl phenol ethoxylates): These are surfactants used to disperse solids (e.g. fluoropolymers) in the liquid phase. These compounds have increasingly been controlled in the EU as there is a concern over their effect in the environment. They are, however, still allowed in fluoropolymer dispersion manufacture.

Sol-gel “Ceramic” Coatings: These coatings are suspensions of tiny particles that react during curing to form a hard, glass-like film. The cured coatings are ceramic-like; they feature many of the same characteristics as ceramics but to a lesser extent. This provides a hard surface, similar to porcelain enamel, and is formulated in a way that allows good release without the use of fluoropolymers (e.g. PTFE).

Globally Harmonized System (GHS): GHS is a United Nations effort to harmonize the classification and labeling of chemicals. GHS contains a toolbox harmonized classification categories, communication elements (e.g. phrases and pictograms), and SDS and labeling requirements. Each country must adopt GHS regulations and all are free to omit portions of the regulation. The fifth revision to GHS was published by the UN in October 2013. These regulations cover the coatings used in manufacturing, and, because of the revisions, individual country modification, and adoption dates, the classification of the same product for different countries may vary. Additional requirements may also apply depending on the country.

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