U.S. EPA Safer Choice and DfE Standard (August 2024)

EPA’s Safer Choice and Design for the Environment (DfE) Standard, August 2024, is the 36-page federal program standard text (plus four annexes A–D of sample partnership-agreement templates) that “establishes minimum requirements for identifying products that meet the U.S. Environmental Protection Agency’s (EPA’s) Safer Choice and DfE program criteria” (§1.1, p. 1). Products meeting the requirements are eligible for either the Safer Choice label (cleaning, detergent, and other formulated chemical products) or the DfE logo (EPA-registered antimicrobial products under FIFRA). Authored by the Office of Pollution Prevention & Toxics (OPPT), the Standard is one of the U.S. EPA’s “most valued partnership programs” (Foreword, p. v), operating under Section 6604(b)(5) of the Pollution Prevention Act (42 USC 13103(b)(5)) and Section 102(2)(J) of the National Environmental Policy Act (42 USC 4332(2)(J)). The Standard was first issued in June 2009 as the DfE Standard for Safer Products, revised in April 2011, September 2012, and February 2015 as EPA’s Safer Choice Standard, and revised again in August 2024. It is the parent document to the Master Criteria for Safer Ingredients (epa2024-safer-choice-master-criteria-ingredients) and to the functional-class criteria documents for surfactants, solvents, fragrances, chelating and sequestering agents, colorants/polymers/preservatives, processing aids, and specialized industrial products that the Safer Choice program publishes on epa.gov/saferchoice.

Heavy-metal relevance of the Standard is concentrated in two clauses. §4.2.5.3 Primary packaging ingredients (p. 18) is a quantitative prohibition: “Primary packaging, including coatings, may not contain heavy metals – specifically cadmium, lead, mercury, and hexavalent chromium – in accordance with Toxics and Packaging Clearinghouse (TPCH) model legislation” (alongside parallel prohibitions on PFAS, BPA, BPS, DBP, DIBP, BBP, DnPP, DEHP, DnOP, DINP, DIDP). The TPCH model legislation referenced (toxicsinpackaging.org/model-legislation/) sets a cumulative Pb+Cd+Hg+Cr-VI cap of 100 ppm in the packaging or packaging component; the Safer Choice Standard adopts that cap by reference for the primary packaging of every certified finished product. §5.9 Toxic Elements (p. 26) is a narrative prohibition at the formulation level: “Safer Choice- and DfE-certified products must not contain toxic elements such as certain heavy metals, as indicated by their hazard profile. Unavoidable de minimis levels may be present, e.g., as components from inorganic materials mined from the earth.” The clause does not name specific elements and does not set a numerical de minimis threshold; in practice the operational threshold is supplied by §3.8.1 ingredient-disclosure cut (incidental ingredients at <0.01 % or <100 ppm are exempt from disclosure) and by §5.12 residuals (residuals of concern capped at <0.01 % or 100 ppm in the formulation). The Standard is held in the Heavy Metal Index corpus as the primary-record citation for the Safer Choice and DfE programs’ product-level and packaging-level treatment of heavy metals, and as the parent document under which the Master Criteria operate.

Key numbers

The Standard contains no contamination measurements. The reportable quantitative content is the set of numerical thresholds, percentages, and pH/composition limits the Standard imposes on certified products and their packaging.

§4.2.5.3 Primary packaging ingredients — heavy-metals prohibition (p. 18)

Primary packaging is defined at §2.1.52 (p. 7) as “a container or separable material component in direct contact with the formulated product.” The TPCH model legislation referenced sets a cumulative concentration limit on Pb+Cd+Hg+Cr-VI in packaging.

§4.2.5.1 Primary packaging — post-consumer recycled content minimums (pp. 17–18)

Multi-material packaging is considered case-by-case. Pump spray-heads, compostable elements, and certain other packaging features may be exempted on rationale. Recycled-content claims are verified via written statements from packaging suppliers.

§4.2.2 pH limits for products as sold (p. 16)

The narrow consumer-products dermal-contact rule (§4.7.3.6, p. 21) is pH ≥ 4 and ≤ 9.5 (with non-irritation testing as the alternative).

§4.2.1 Performance criteria (pp. 14–16)

§4.2.6 VOC content (p. 18)

VOC content of certified products must adhere to the more-stringent of the Ozone Transport Commission (OTC) Phase V Model Rule and the California Air Resources Board (CARB) Regulation for Reducing Emissions from Consumer Products. For product categories not addressed by CARB, partners must demonstrate best efforts to minimise VOCs.

§4.2.7 Flammability (pp. 18–19)

Certified products must not exhibit the characteristic of ignitability per 40 CFR 261.21(a)(1); flash point must be ≥ 60 °C (140 °F) as determined by ASTM E502 closed-cup method. Exception: aqueous solutions containing < 24 % alcohol by volume, where alcohol is required for product function (e.g., certain disinfectants).

§4.2.8 Yellow-triangle content limit (p. 19)

Chemicals on the Safer Chemical Ingredients List (SCIL) carrying a yellow-triangle designation must not cumulatively exceed 10 % of a certified product as sold.

§3.8.1 Ingredient-disclosure threshold (p. 13)

Incidental ingredients (residual amounts present without technical or functional effect, per 21 CFR 701.3(l)) are exempt from disclosure if present at < 0.01 % or < 100 ppm in the formulation.

§5.12 Residuals (p. 27)

Residuals of concern (residuals that fail the carcinogenicity, mutagenicity, reproductive-toxicity, or other-human-health-effects criteria, or fail the Final PB&T Rule for persistence, bioaccumulation, and toxicity) are limited to < 0.01 % (< 100 ppm) by weight in the formulation. Where another federal regulatory restriction sets a stricter limit on a given chemical or product type, the stricter limit applies. Dilution may not be used to satisfy the residuals limit in concentrates.

§5.15 Oxidant stabilisers — phosphorus carve-out (p. 28)

Phosphates are generally not allowed in Safer Choice / DfE-certified products. Single exception: phosphorus may be used as an oxidant stabiliser at up to 0.5 % (5,000 ppm) in a certified product, on the rationale that no safer alternative is currently available.

§5.5.1 Fragrance skin-sensitiser limit (p. 25)

Each fragrance material that is a skin sensitiser is limited to no more than 0.01 % (100 ppm) in the final product, with disclosure-and-monitoring provisions allowing higher levels in limited circumstances.

§5.4.2 d-Limonene as a solvent ingredient (p. 24)

d-Limonene may be used in Safer Choice / DfE-certified products only at concentrations at which potential oxidation products may be present at 20 mmol/L or less, corresponding to a limonene concentration of 1.36 % or less in the overall formulation. d-Limonene may not be used in combination with oxidisers (e.g., H₂O₂), nor in direct-release products (per §4.8.1).

§5.9 Toxic Elements — narrative formulation-level prohibition (p. 26)

“Safer Choice- and DfE-certified products must not contain toxic elements such as certain heavy metals, as indicated by their hazard profile. Unavoidable de minimis levels may be present, e.g., as components from inorganic materials mined from the earth.”

The clause does not name specific elements, does not set a numerical de minimis threshold, and does not specify how “hazard profile” is operationalised; in practice the operational thresholds are the §3.8.1 ingredient-disclosure cut (<0.01 % / <100 ppm), the §5.12 residuals cap (<0.01 % / <100 ppm), and the Master Criteria authoritative-list trip-wires (Prop 65, IARC, NTP, EU CLP, NIOSH) that fail any heavy-metal compound carrying a relevant classification regardless of concentration.

§5.2.1 Authoritative-list exclusions applied to all certified products (pp. 23–24)

• §5.2.1.1 Hazardous Air Pollutants (HAPs): chemicals on EPA’s HAP list (epa.gov/haps/initial-list-hazardous-air-pollutants-modifications) are excluded except where they meet Safer Choice Criteria.
• §5.2.1.2 Toxics Release Inventory (TRI): chemicals on EPA’s TRI chemical list are excluded except where they meet Safer Choice Criteria.
• §5.2.1.3 Carcinogens, mutagens, reproductive toxicants: chemicals on IARC (Groups 1, 2A, 2B), NTP, IRIS, NIOSH, European Commission, California Prop 65 lists are excluded except for exemptions based on physical-form or extreme-pH properties that do not pertain to certified products.
• §5.2.1.4 PBTs / vPvBs: chemicals on EU REACH Substances of Very High Concern, Stockholm Convention POPs, and OSPAR List of Substances of Possible Concern lists are excluded.
• §5.2.1.5 Endocrine-disruption flagging: ECHA Endocrine Disruptor Assessment List and US EPA Endocrine Disruptor Screening Program priority list flag chemicals for additional evaluation.

§5.6 Chelating and sequestering agents (p. 25)

Phosphorus-containing chelating chemistries that contribute to eutrophication are excluded. Nitrilotriacetic acid (NTA, a potential carcinogen) is excluded by name. Chelating agents with molecular weight > 1,000 are evaluated under the polymer criteria. The §2.1.17 definition of “chelating agent” notes that chelating agents “can change the properties of metal ions, help to transport metal ions, and prevent scale formation.”

§5.11 Disposable wipes (p. 27)

Substrate must be natural fibres (cotton, bamboo) or biodegradable synthetic fibres from renewable sources, demonstrated via EN13432, ASTM 6400, ASTM 5338, ISO 14855, or similar. A “Do Not Flush” symbol must be prominently displayed.

Section 7 — Safer Choice Cleaning Service Certification (pp. 31–34)

A separate certification path for cleaning service providers (residential cleaners, commercial cleaners, facility managers, owners, government entities with in-house cleaning services). Eligibility requires using Safer Choice-certified products for cleaning and DfE-certified products for disinfecting “to the maximum extent practicable” (§7.3.1). Exception path allows a one-year exemption per product class with documented rationale. Annual audits via Cleaning Service Certification (CSC) Profilers.

Methods (brief)

Not applicable. This is a federal program standard, not an experimental study; there is no sampling, no analytical instrumentation, no contamination measurements. The “method” content of the Standard is its specification of (a) acceptable performance test methods for each product class (§4.2.1, summarised in the Key numbers table above), (b) the Master Criteria’s toxicological evaluation test methods for ingredient safety (the Master Criteria’s §6, documented in epa2024-safer-choice-master-criteria-ingredients), and (c) administrative methods for partnership compliance (Annexes A–D, §3.6 audits via third-party profilers under ISO/IEC Guide 17065, §C desk and on-site audits).

Speciation. The Standard distinguishes hexavalent chromium (Cr-VI) from total Cr in §4.2.5.3 (the packaging-ingredients prohibition names Cr-VI explicitly, not total Cr). Mercury, lead, and cadmium are named at the elemental level without species qualification; the TPCH model legislation incorporated by reference treats them as total elemental Cd, Pb, Hg in packaging. The §5.9 narrative formulation-level clause does not name specific elements and does not specify speciation.

Basis. Concentrations in §4.2.5.3 packaging are governed by the TPCH model legislation referenced by URL; that legislation specifies a cumulative cap on Pb+Cd+Hg+Cr-VI in packaging material on a weight basis (commonly read as 100 ppm cumulative). The §5.12 residuals cap (<0.01 % / <100 ppm) and §3.8.1 incidental-ingredient cut (<0.01 % / <100 ppm) are expressed in weight-percent in the finished formulation. The §5.15 phosphorus oxidant-stabiliser cap (0.5 % / 5,000 ppm) is in the certified product. The §5.5.1 fragrance skin-sensitiser cap (0.01 % / 100 ppm) is in the final product.

Implications

• The Standard is the federal-government primary record under which the U.S. EPA Safer Choice and DfE programs operate. It anchors the regulatory-context layer of HMI’s household-cleaning-product matrix as the parent document for epa2024-safer-choice-master-criteria-ingredients and for the functional-class criteria documents (surfactants, solvents, fragrances, chelating agents, colorants/polymers/preservatives, processing aids, specialized industrial products) referenced throughout the Standard’s §5.
• The §4.2.5.3 packaging prohibition on Cd, Pb, Hg, and Cr-VI (referencing the TPCH model legislation) is the Standard’s most quantitatively specific heavy-metal clause; the cumulative TPCH cap (commonly 100 ppm sum of the four elements in packaging or packaging components) is one of the few binding numerical heavy-metal limits the Safer Choice program sets on certified products. It sits alongside state-level enactments of TPCH model legislation (e.g., California, Connecticut, Florida, Illinois, Iowa, Maine, Maryland, Minnesota, Missouri, New Jersey, New Hampshire, New York, Pennsylvania, Rhode Island, Vermont, Washington, Wisconsin) that turn the TPCH limits into binding state law for packaging sold in those jurisdictions. Recent state additions (e.g., Washington and Maine adding PFAS and phthalates beyond the TPCH four-metal core) are not reflected in the Safer Choice Standard but are tracked separately by TPCH.
• The §5.9 formulation-level “toxic elements” clause is narrative rather than numerical: it names no specific elements and sets no de minimis concentration. Its operational meaning depends on the §3.8.1 ingredient-disclosure threshold (<100 ppm), the §5.12 residuals cap (<100 ppm), and the Master Criteria authoritative-list trip-wires (Prop 65, IARC, NTP, EU CLP) that fail heavy-metal compounds carrying a relevant classification regardless of formulation concentration. HMI sessions reasoning about how Safer Choice handles trace heavy-metal contamination in cleaning-product ingredients should read this clause in conjunction with the Master Criteria’s §5.2 (carcinogenicity, p. 10), §5.3 (genetic toxicity, p. 12), §5.6 (reproductive and developmental toxicity, p. 16), and the Master Criteria’s authoritative-list cross-references; the Standard alone does not specify a numerical heavy-metal limit at the formulation level.
• The §5.6 chelating-agents clause is relevant to HMI because chelating agents act on metal ions specifically. The Standard’s narrative restriction on NTA (named as a potential carcinogen) and on phosphorus-containing chelators is upstream of any HMI synthesis on metal mobility, bioavailability, and capture in cleaning chemistries. Phosphorus is out of HMI scope; the §5.15 phosphorus oxidant-stabiliser carve-out (0.5 % / 5,000 ppm) is recorded here for regulatory-context completeness.
• The Standard does not propose HMTc-relevant threshold values for any heavy metal in any food, personal-care, or household-product matrix. No threshold values are proposed by this source page.

Limitations

• No original measurements. The Standard is a program document, not an experimental or surveillance study. No sample sizes, no analytical methods (other than the performance-test references in §4.2.1 and the toxicology test-method references in the Master Criteria §6), no concentration values for any heavy-metal contaminant in any certified product, no detection frequencies.
• No quantitative heavy-metal threshold at the formulation level. §5.9 is narrative and unquantified. The Standard provides quantitative heavy-metal limits only for primary packaging (§4.2.5.3, via TPCH reference) and only for the four elements Cd/Pb/Hg/Cr-VI. Other heavy metals (e.g., As, Ni, Al, Sn, Sb, U) are not named in §4.2.5.3 and are not addressed numerically anywhere in the Standard; they are governed only by the Master Criteria’s authoritative-list trip-wires and the general §5.9 narrative.
• Programme is voluntary, not regulatory. Safer Choice and DfE are EPA-administered voluntary certification programmes, not regulations enforced under TSCA, CPSA, FIFRA (for the Safer Choice label; FIFRA does govern DfE-registered antimicrobials), or any other US statute. A chemical or product failing the Standard is not, by that fact alone, prohibited in commerce; it is excluded from products bearing the Safer Choice label or DfE logo. The Standard is “primary record” for the programme requirements, not for any binding heavy-metal limit in US law.
• TPCH cap is incorporated by reference, not stated numerically. §4.2.5.3 names the four banned metals (Cd, Pb, Hg, Cr-VI) but does not state the cumulative concentration cap (commonly 100 ppm sum) in the Standard text itself; the cap lives in the TPCH model legislation at toxicsinpackaging.org/model-legislation/. HMI sessions reasoning about the actual numerical limit must consult the TPCH model legislation directly; the Safer Choice Standard’s own text does not assert the number.
• Master Criteria is the working ingredient-evaluation document. §5.2 of the Standard refers all general ingredient-acceptance criteria back to the Master Criteria for Safer Ingredients (epa2024-safer-choice-master-criteria-ingredients). HMI sessions reasoning about how a specific heavy-metal compound is screened under Safer Choice must read both documents together; the Standard alone is incomplete on ingredient acceptance.
• Functional-class criteria not in this document. Surfactants, solvents, fragrances, chelating/sequestering agents, colorants/polymers/preservatives, processing aids/additives, and specialized industrial products each have their own functional-class criteria documents on epa.gov/saferchoice that are normative when they apply (§5.3–§5.18 of the Standard cite each by URL). The Standard provides only the framing rules and the residual / fallback requirements; the binding functional-class limits are elsewhere.
• English-only, US jurisdiction. Document is in English and frames its requirements against US federal authorities (US EPA, NTP, NIOSH, OEHHA Prop 65, FDA, OSHA, DOT, FTC) together with international references (GHS, OECD, IARC, ECHA REACH, Stockholm Convention POPs). Other jurisdictions’ equivalent voluntary-eco-label programmes (e.g., EU Ecolabel, Nordic Swan, Green Seal) operate under their own standard documents not addressed here.
• August 2024 publication date; authoritative lists and TPCH model legislation evolve. The HAP list, TRI list, IARC monographs, NTP RoC, IRIS assessments, NIOSH carcinogen list, Prop 65 list, REACH SVHC list, Stockholm POPs annexes, OSPAR list, and TPCH model legislation all change between the Standard’s August 2024 publication date and the date an HMI session reads it. Downstream synthesis citing this document should re-check the live status of any specific compound classification and the current TPCH model-legislation text.

Provenance

• Source PDF: raw/manual-fetch/Kimi_Agent_Download Corruption Issue/household_papers/06_Regulatory_EPA_GreenSeal/EPA_Safer_Choice_Standard_2024.pdf
• SHA-256: 0472867c600ed1d52491749bf9e8ebc6c090175c00e4d674534fd96f5cb9978f
• File size: 911 KB; document body §§1–8 on pp. 1–36 plus Annexes A–D (sample partnership-agreement templates for Safer Choice partners, DfE partners, on-site/desk audits, and Safer Choice Cleaning Service Partnership). Front matter: cover, ToC pp. i–iv, Foreword pp. v–vii.
• Publisher: U.S. Environmental Protection Agency, Office of Pollution Prevention & Toxics (OPPT), Washington, DC.
• Programme home page: epa.gov/saferchoice (Safer Choice and Design for the Environment programmes). Standard page: epa.gov/saferchoice/standard.
• Document title (cover): “EPA’s Safer Choice and Design for the Environment (DfE) Standard.”
• Revision history (cover): June 2009 (formerly the ‘DfE Standard for Safer Products’); revised April 2011, September 2012, and February 2015 (formerly, ‘EPA’s Safer Choice Standard’); August 2024 (current).
• DOI: none assigned (federal-agency program document).
• License: U.S. Government Work (public domain under 17 USC § 105).
• Access date: 2026-06-03.
• Acquisition path: included in Kimi Agent Download Corruption Issue (KADC) folder household_papers/06_Regulatory_EPA_GreenSeal/, alongside the Master Criteria for Safer Ingredients and other regulatory and voluntary-standards content (David Suzuki Foundation, EU Ecolabel, Green Seal GS-37/GS-52/GS-8, NIOSH HHE, California SB258 right-to-know, New York State Cleaning Product Disclosure).

Wiki pages this source may touch

• epa2024-safer-choice-master-criteria-ingredients — child criteria document referenced as Standard §5.2; reads in conjunction with this page for ingredient evaluation.
• all-purpose-cleaners — within Safer Choice scope (§1.2.1; §4.2.1.2). Broad product context.
• appliance-cleaners — within scope. Broad product context.
• automatic-dishwasher-detergents — within scope. Broad product context.
• bathroom-tub-tile-cleaners — within scope (§4.2.1.4). Broad product context.
• carpet-cleaners — within scope (§4.2.1.3). Broad product context.
• dish-soaps-manual — within scope (§4.2.1.8). Broad product context.
• drain-maintainers-cleaners — within scope (§4.2.1.11 biological-based drain products). Broad product context.
• floor-cleaners-hard-surface — within scope. Broad product context.
• household-specialty-cleaners-other — catch-all for cleaning products not in a more specific category (§1.2.1 names graffiti removers and boat/car care; §4.8.1 direct-release products). Broad product context.
• kitchen-countertop-cleaners — within scope. Broad product context.
• laundry-detergents — within scope (§4.2.1.6; §4.2.7.1 industrial). Broad product context.
• laundry-detergent-boosters-additives — within scope. Broad product context.
• laundry-prewash-products — within scope (§4.2.1.6 pre-wash spotter). Broad product context.
• oven-grill-bbq-cleaners — within scope (§4.2.1.7). Broad product context.
• pre-treaters-stain-removers — within scope. Broad product context.
• toilet-bowl-cleaners — within scope (§4.2.1.4). Broad product context.
• window-glass-mirror-cleaners — within scope (§4.2.1.1). Broad product context.

Verification notes

• Identity-check results on 2026-06-03 against wiki/sources/: DOI null (federal-agency standard document, no DOI assigned); raw_handle grep for KADC_epa-safer-choice-standard-2024 returned no matches; cite-key grep for epa2024-safer-choice-standard returned no matches. Ingested as NEW. Sibling page epa2024-safer-choice-master-criteria-ingredients (the child Master Criteria document) is a distinct EPA publication; the parent Standard ingested here was explicitly noted as missing from the corpus by the Master Criteria source page’s verification notes and is now added.
• SHA-256 of the source PDF was computed from disk on 2026-06-03 (0472867c600ed1d52491749bf9e8ebc6c090175c00e4d674534fd96f5cb9978f).
• The document has no DOI (federal-agency program-standard document, not a journal article). doi is null.
• Evidence tier set to A on the basis of: (i) authoritative federal-agency primary record from US EPA OPPT, the office that administers Safer Choice and DfE; (ii) explicitly versioned (June 2009, revised April 2011, September 2012, February 2015, August 2024) and dated criteria text; (iii) document is the primary source of its own assertions (no secondary-source dependence for the Standard’s requirements themselves); (iv) published openly via the epa.gov/saferchoice programme web presence.
• License set to “U.S. Government Work (public domain, 17 USC § 105)” because the document is authored by a federal agency in the course of official duties; per 17 USC § 105 such works are not subject to copyright in the United States.
• Source type set to gov-guidance rather than gov-regulation because Safer Choice and DfE are voluntary certification programmes administered by EPA, not statutory regulations under TSCA or any other US law. (The DfE program reviews antimicrobials that are themselves regulated under FIFRA; that does not make the DfE Standard itself a FIFRA regulation.)
• metals: [Cd, Pb, Hg, Cr-VI] is the set of elements explicitly named in §4.2.5.3 (the packaging-ingredients prohibition). The §5.9 narrative clause does not name specific elements and so does not enlarge this set. Cr-VI is used (not Cr) because §4.2.5.3 names hexavalent chromium specifically; Hg is used (not MeHg or tHg) because the TPCH model legislation referenced in §4.2.5.3 treats Hg as total elemental mercury in packaging at the cumulative-cap level, not as a speciated value.
• ingredients: [] is intentional: the document is generic standard text covering all cleaning-product ingredient classes, not specific to any one ingredient.
• products: [...] lists every household-cleaning-product taxonomy slug currently in wiki/products/ that is within Safer Choice / DfE scope per §1.2.1, §4.2.1, and §4.8 (the programme covers all formulated cleaning and detergent products broadly, plus EPA-registered antimicrobials via DfE; Direct Release products such as graffiti removers and boat/car cleaners — §1.2.1 examples — are caught by household-specialty-cleaners-other). Routing fan-out is broad_product_context, not direct_evidence, because no contamination values are reported in the Standard text. Where a product class has a specific performance threshold in §4.2.1, the page-level wikilink notes the relevant subsection; the routing remains broad-product-context because performance testing is not heavy-metal evidence.
• matrices: [household-cleaning-product] matches the matrix already in use on epa2024-safer-choice-master-criteria-ingredients, davidsuzuki2014-toxic-household-cleaners, and ecetoc1992-tr045-ni-co-cr-consumer-products.
• jurisdictions: [US] because the document is the federal-government standard text from US EPA. The Standard cross-references EU CLP, GHS, OECD, IARC, ECHA REACH, Stockholm Convention, OSPAR, and TPCH (a US-state-led model legislation initiative); the Standard document itself is the US-jurisdictional primary record.
• Wiki/HMTc firewall (Part 2): the document is upstream of any HMTc threshold-setting work; no Part 2 drift risk in the body of this page. The Implications section does not propose HMTc threshold values and explicitly states none are proposed.
• Brand firewall (Part 12): the document does not name any brand of cleaning product. No brand-firewall action required. The Standard does reproduce the Safer Choice label and DfE logo trademarks themselves (§6.2.1, §6.2.2 figures); these are the program marks, not commercial brand names, and are not in scope for Part 12.
• The §4.2.5.3 packaging Cd/Pb/Hg/Cr-VI prohibition references the TPCH model legislation but does not state the cumulative concentration cap (commonly 100 ppm) inside the Standard text itself. The implications and limitations sections record this incorporation-by-reference rather than asserting the numerical cap as a claim of the Standard. An HMI session looking up the actual numerical TPCH cap should consult the TPCH model legislation directly at toxicsinpackaging.org/model-legislation/.
• The §5.9 “Toxic Elements” clause is the only formulation-level (as opposed to packaging-level) heavy-metal clause in the Standard, and is narrative rather than numerical. It is reproduced verbatim above. No numerical de minimis is given in the Standard; the operational thresholds (§3.8.1 disclosure cut, §5.12 residuals cap) and the Master Criteria authoritative-list trip-wires are what give §5.9 operational meaning in practice.
• Quantitative content in this page (tables for §4.2.5.3 packaging banned classes; §4.2.5.1 recycled-content minimums; §4.2.2 pH; §4.2.1 performance; §3.8.1 disclosure cut; §5.12 residuals; §5.15 phosphorus carve-out; §5.5.1 fragrance sensitiser; §5.4.2 d-limonene) is reproduced exactly from the source PDF (August 2024 revision) with page locators throughout.
• No new ingredient pages and no new product pages were created during this ingest, per CLAUDE.md Part 10 and the skill’s hard constraints. The product list in frontmatter draws only on existing wiki/products/ slugs.
• No new regulation page was created. If a regulations/epa-safer-choice-standard.md page is ever needed (Step 0 Lock decision), it would inherit from this Standard as the parent document and from the Master Criteria (epa2024-safer-choice-master-criteria-ingredients) as the child ingredient-evaluation document, plus the functional-class criteria documents on epa.gov/saferchoice as the binding-when-applicable normative references. The TPCH model legislation referenced by §4.2.5.3 is a separate regulatory document not in the present KADC PDF set and would warrant its own source page if pulled into the wiki.

Page history

The five most recent substantive edits to this page. The full version history lives in git; when DOI minting comes online (see schema docs), each entry below will also link to a version-pinned DataCite DOI.