Forthcoming Vermont PFAS Ban deadline

Further to the forthcoming regulation changes in certain US states that will ban PFAS (per- and polyfluoroalkyl substances) used in the manufacturing of food and beverage packaging, Canlab is taking the opportunity to remind customers that Vermont will be the first state to implement a PFAS ban from the 1st July, 2023. 

PFAS may be present in trace amounts as PTFE (polytetrafluoroethylene) wax which are present in some materials used to manufacture exterior coatings, inks and end internal coatings that are used by the can makers in the manufacturing process of aluminum beverage cans or aluminum end closures. 

New coatings
After the 1st July 2023, aluminum beverage cans or aluminum end closures made by our suppliers which have not transitioned to the new coatings (see below), cannot be intended for sale, use, or distribution for sale or use in the State of Vermont. Accordingly, you will need to transition these products to these new coatings prior to that date. 

Our suppliers are currently working with their suppliers to provide a coatings solution that will be compliant with the new legislation and which you may wish to take advantage of. Thus far early trials in the various plants have been positive and our suppliers hope to have a transition plan to share over the coming months as they complete the trials. Our suppliers are assessing the costs associated with supplying the new coatings and will communicate these in due course. 

More PFAS bans
Canlab is aware that in addition to Vermont, Connecticut (Dec-23), Minnesota (Jan-24) and Maryland (Jan-24) have announced PFAS bans and we anticipate that a number of other US States, countries and territories may follow suit by implementing similar bans. 

Some are implementing labelling requirements and/or declarations around products containing PFAS materials, such as Maine (Jan-23) and California (Feb-23). 

In good faith
To help you plan effectively, Canlab will continue to share useful industry related information that we are made aware of from time to time. However, all such information whether in this letter or in future communications is provided in good faith, it does not constitute legal advice. It is important that you take your own independent compliance and legal advice in each state, country and territory that you do business in to ensure that you are aware of your ongoing compliance obligations in a timely manner. 

We remain at your disposal and please reach out to your contact with any additional questions.