Over the past two decades, people have become increasingly interested in what they are exposed to and more specifically what comes into contact with their bodies. This is, in part because of social media and people being able to share information in ways not previously available but also the number of documentaries highlighting the impacts of consumer goods and the invisibility of modern comfort—the perfectly soft toilet paper, the stain resistant carpets and the fast-acting grease-dissolving household cleaners.

Yet the decisions we make daily and over time, can have profound impacts on our bodies and health. Adopted to limit the intentional use of certain heavy metals and other chemicals of concern in packaging, the TPCH Model provides a framework for testing, transparency and accountability that remains relevant today.

What Is The TPCH Model?

Established in 1992, the TPCH Model Legislation established strict, uniform rules for disposable packaging and packaging components to keep hazardous substances out of landfills, incinerators, and recycling:

Zero Intentional Use: It strictly prohibits the intentional addition of four specific heavy metals during the manufacturing process.100 ppm 

Limit: Even if there is no intentional use, the total concentration of these four heavy metals combined must not exceed 100 parts per million (ppm) by weight.

The model restricts the sum of four intentionally introduced heavy metals, including lead, cadmium, mercury and chromium VI (the worst kind), to no more than 100 parts per million (ppm). These substances are regulated because, at elevated levels, they are associated with potential human and environmental health concerns.  

• Lead—linked to developmental issues, especially in children

• Cadmium—can build up in the body and affect the kidneys

• Mercury—toxic to the nervous system and harmful to wildlife

• Chromium VI—a skin irritant and carcinogen

The TPCH model did not officially expand to consumer goods; rather, the toilet paper industry (and others) proactively adopted TPCH testing standards. Because toilet paper is a paper product, in its manufacturing chain, you see material and chemical overlap, in addition to wastewater contamination concerns that mirrors paper-based packaging production. For example, some toilet paper manufacturers use PFAS during pulp processing to prevent paper from sticking to machinery or to add wet-strength.

In 2021, the US TPCH issued an update to its Model Legislation. The revised Model Legislation included:

• And expanded list of regulated chemicals to include (ortho) phthalates and perfluoroalkyl and polyfluoroalkyl substances (PFAS) — as you have seen, we talk about the no intentionally added PFAS confirmed by SGS

• Adds new processes and criteria for identifying and regulating additional chemicals of high concern in packaging

• Provides a new definition for ‘Post-consumer recycled material’

This update came at a time where PFAS contamination was an increasing area of focus for the scientific community. PFAS had been identified in human serum and toilet paper had been identified as a potentially major source of PFAS contamination entering wastewater treatment systems.

How EcoRoll approaches chemical transparency

Understanding what is in a product begins with testing and transparency. While no testing programme can screen for every substance that may exist within a complex global supply chain, independent verification provides an important layer of accountability.

EcoRoll toilet paper is tested by Société Générale de Surveillance SA (SGS), an independent laboratory, in accordance with the Toxics in Packaging Clearinghouse (TPCH) Model. This testing verifies compliance with limits for lead, cadmium, mercury and chromium VI, while also supporting our broader approach to avoiding the intentional use of chemicals of concern.

In addition to TPCH testing, our suppliers have undertaken independent PFAS screening. Testing performed by SGS found no detectable PFAS, with results below the laboratory method detection limit. Together, these assessments provide additional assurance that our toilet paper meets recognised standards for chemical compliance and material transparency.

For us, chemical transparency is not about making alarmist claims. It is about understanding what goes into the products we use every day and providing customers with information that helps them make informed decisions.