State-Level Packaging Regulations in the U.S.: A Corrugated Industry Overview

The United States has no single, comprehensive federal packaging regulation. Instead, packaging is governed by a patchwork of state-level laws that vary in scope, stringency, and enforcement. For corrugated packaging manufacturers and the companies that purchase corrugated boxes, this fragmented regulatory landscape creates compliance complexity that scales with geographic reach — the more states you sell into, the more regulations you must navigate.

This overview covers the major categories of state-level packaging regulation that affect the corrugated industry, identifies the states with the most impactful requirements, and provides a framework for managing multi-state compliance.

Toxics in Packaging Laws

The Model Legislation: CONEG/TPCH

The most widely adopted category of state packaging regulation is the Toxics in Packaging Prevention Act, based on model legislation originally developed by the Coalition of Northeastern Governors (CONEG) and now maintained by the Toxics in Packaging Clearinghouse (TPCH).

This model law restricts the sum total concentration of four heavy metals in packaging and packaging components to 100 parts per million (ppm):

Lead
Mercury
Cadmium
Hexavalent chromium

As of 2026, 19 states have enacted versions of this legislation:

Connecticut, Florida, Georgia, Illinois, Iowa, Maine, Maryland, Minnesota, Missouri, New Hampshire, New Jersey, New York, Pennsylvania, Rhode Island, Vermont, Virginia, Washington, Wisconsin, and California (which has separate but overlapping requirements).

What This Means for Corrugated

Standard corrugated board manufactured from virgin kraft or recycled containerboard, with water-based flexographic inks and starch-based adhesives, generally complies with the 100 ppm heavy metals limit without difficulty. However, compliance cannot be assumed — it must be verified.

Potential sources of non-compliance in corrugated packaging include the following.

Printing inks. Some pigments, particularly yellow and orange, can contain trace amounts of lead or cadmium. Modern ink formulations from reputable suppliers have largely eliminated these metals, but older or imported inks may contain higher levels.

Recycled content. Recycled containerboard can contain trace heavy metals introduced through the recycled fiber stream. While concentrations are typically well below 100 ppm, high recycled content board should be tested periodically.

Coatings and surface treatments. Specialty coatings, particularly metallic or pearlescent finishes used on premium retail packaging, may contain regulated metals.

Compliance approach. Request Certificates of Compliance (CoC) from your containerboard suppliers, ink manufacturers, and coating suppliers confirming that their products meet the TPCH 100 ppm threshold. Most major suppliers provide these certificates routinely. Conduct periodic third-party testing of finished corrugated packaging to verify compliance, particularly when changing material suppliers.

Extended Producer Responsibility (EPR) Laws

EPR for packaging represents the most significant new category of state packaging regulation. These laws shift the financial responsibility for end-of-life packaging management from municipalities to the producers (brand owners and importers) who introduce packaging into the market.

As covered in detail in our EPR state-by-state guide, four states have enacted comprehensive EPR laws for packaging:

Maine (LD 1541, enacted 2021)
Oregon (SB 582, enacted 2021)
Colorado (HB 22-1355, enacted 2022)
California (SB 54, enacted 2022)

Additional states including New York, Washington, Illinois, and Maryland are actively considering EPR legislation.

Corrugated-Specific EPR Considerations

Corrugated packaging benefits from favorable treatment under EPR laws due to its high recyclability, established recycling infrastructure, and significant recycled content. Eco-modulated fee structures in all four enacted EPR laws are expected to result in lower per-ton fees for corrugated compared to harder-to-recycle materials.

However, companies must still comply with producer registration, volume reporting, and fee payment requirements. For businesses operating nationally, managing EPR compliance across multiple states with different PROs, reporting timelines, and fee structures requires dedicated compliance resources.

Recycled Content Mandates

Several states have enacted or are considering laws requiring minimum levels of recycled content in packaging.

California (SB 343 and AB 793)

California has multiple laws affecting recycled content in packaging. While AB 793 specifically targets plastic beverage containers, the broader regulatory trend toward recycled content mandates is relevant to corrugated. The state's SB 54 (the EPR law) includes provisions that incentivize recycled content through eco-modulated fees.

For corrugated, recycled content is generally not a compliance challenge. Approximately half of all containerboard produced in North America is manufactured from recycled fiber, and many corrugated boxes contain 30 to 100 percent recycled content by default.

Washington (SB 5022)

Washington's recycled content law targets plastic packaging but reflects a broader trend. As more states adopt recycled content mandates, corrugated's inherently high recycled content positions it favorably compared to competing materials.

Truth-in-Labeling for Recyclability

California SB 343

This law, effective January 2024, prohibits the use of the "chasing arrows" recycling symbol on packaging unless the material is actually recyclable in California's curbside recycling programs. The law targets misleading recyclability claims and requires that the material meet specific recyclability thresholds.

Standard corrugated board qualifies as recyclable under SB 343 — it is accepted in virtually all curbside recycling programs in California. However, corrugated with certain coatings (petroleum wax), laminations, or contamination may not qualify. If your corrugated packaging carries a recycling symbol, verify that the specific packaging construction (including any coatings or laminations) meets the recyclability criteria.

FTC Green Guides

While federal rather than state, the Federal Trade Commission's Green Guides govern environmental marketing claims nationwide, including claims about recyclability, recycled content, and compostability. These guidelines affect how corrugated packaging can be marketed in all states.

Key requirements for corrugated packaging claims:

"Recyclable" claims. Unqualified "recyclable" claims are appropriate for standard corrugated because recycling is available to a substantial majority of consumers. However, wax-coated or heavily laminated corrugated should not make unqualified recyclability claims.
"Recycled content" claims. Must be accurate and specify pre-consumer vs. post-consumer recycled content. Document recycled content percentages with supplier certifications.
"Compostable" claims. If corrugated packaging claims to be compostable, it should meet ASTM D6400 or D6868 standards for compostability in commercial composting facilities.

Packaging Reduction and Source Reduction Laws

Oregon (Rigid Plastic Packaging Container Act)

Oregon's law requires that rigid plastic packaging meet one of several criteria, including recycled content thresholds, recyclability, or reuse. While primarily targeting plastic, the law reflects a regulatory trend toward mandatory source reduction that could eventually extend to all packaging materials.

New Jersey (Packaging Reduction)

New Jersey has periodically considered packaging reduction legislation. While no comprehensive law has been enacted specifically targeting corrugated, the state's environmental regulatory framework includes waste reduction goals that affect packaging.

Multi-State Trend

The broader trend across states is toward rewarding packaging that minimizes material use while maintaining functionality. For corrugated, this aligns with industry practices like right-sizing, lightweighting (using lower basis weight containerboard where performance allows), and eliminating unnecessary packaging components.

PFAS Restrictions

Per- and polyfluoroalkyl substances (PFAS) used in food-contact packaging — including grease-resistant corrugated — are facing increasing state-level restrictions.

States with PFAS Packaging Bans or Restrictions

As of 2026, the following states have enacted laws restricting PFAS in food-contact packaging:

Maine — Banned all intentionally added PFAS in food packaging (effective 2023)
Washington — Banned PFAS in food packaging (effective 2023)
New York — Banned PFAS in food packaging (effective 2023)
California — Banned PFAS in food packaging (AB 1200, effective 2023)
Connecticut, Maryland, Minnesota, Vermont, Rhode Island, Colorado, Hawaii — Various PFAS packaging restrictions enacted or effective

Impact on Corrugated

These laws directly affect corrugated packaging used for food-contact applications that require grease or moisture resistance. The corrugated industry has responded by developing PFAS-free barrier coatings and water-based alternatives that provide functional moisture and grease resistance without PFAS chemistry.

For corrugated converters and users of food-contact corrugated, ensuring PFAS-free compliance requires confirming that all barrier coatings, sizing agents, and surface treatments used on food-contact packaging are PFAS-free. Request PFAS-free certifications from all material suppliers in the food-contact packaging supply chain.

Plastic Bag Bans and Corrugated Opportunity

While not directly regulating corrugated packaging, the wave of state and local bans on single-use plastic bags has created secondary demand for corrugated alternatives. Retailers shifting from plastic bags to paper-based alternatives often specify corrugated-based solutions for shipping and storage within their supply chains.

States with comprehensive plastic bag bans or restrictions include California, New York, Oregon, Washington, Connecticut, Delaware, Hawaii, Maine, New Jersey, and Vermont, with numerous additional local ordinances in other states.

Managing Multi-State Compliance

Compliance Framework

For companies selling corrugated-packed products in multiple states, managing the patchwork of regulations requires a systematic approach.

Step 1: Map your exposure. Identify every state where your packaged products are sold. This determines which state regulations apply to your business.

Step 2: Create a compliance matrix. Build a matrix of applicable regulations by state, covering toxics in packaging, EPR, recycled content, labeling, and PFAS requirements. Update this matrix at least annually.

Step 3: Specify compliant materials. Work with your corrugated converter to ensure that your packaging materials — board, inks, coatings, and adhesives — comply with the most stringent applicable requirements across all states where you sell. This "comply to the strictest standard" approach simplifies production and eliminates the risk of shipping non-compliant packaging to a state with stricter requirements.

Step 4: Maintain documentation. Keep current Certificates of Compliance from all material suppliers, testing records for heavy metals and PFAS, recycled content certifications, and EPR registration and reporting records.

Step 5: Monitor regulatory changes. Subscribe to regulatory monitoring services, participate in industry association regulatory updates (FBA, AF&PA, AMERIPEN), and maintain relationships with state regulatory contacts. The regulatory landscape is evolving rapidly, and new requirements can have short compliance timelines.

Industry Resources

Several industry organizations provide compliance support for corrugated packaging companies navigating state-level regulations.

Fibre Box Association (FBA): Provides regulatory updates, compliance guidance, and advocacy for the corrugated industry
American Forest and Paper Association (AF&PA): Broader paper and packaging industry regulatory monitoring
AMERIPEN (American Institute for Packaging and the Environment): Packaging-focused policy advocacy and compliance resources
Toxics in Packaging Clearinghouse (TPCH): Administers the Model Toxics in Packaging Legislation and provides compliance tools

The Outlook

The direction of state-level packaging regulation is clear: more states, more requirements, and more enforcement. EPR is expanding. PFAS restrictions are proliferating. Recyclability and recycled content requirements are tightening. And the administrative burden of multi-state compliance is growing.

For the corrugated industry, the regulatory trend is broadly favorable. Corrugated packaging's high recyclability, significant recycled content, established recycling infrastructure, and move away from PFAS chemistry position it well relative to competing materials. But favorable positioning does not eliminate compliance obligations. Companies that build robust compliance systems now — with documented material specifications, supplier certifications, and regulatory monitoring — will avoid costly disruptions as the regulatory landscape continues to evolve.