【Washington, D.C.】The U.S. Consumer Product Safety Commission (CPSC) officially issued a regulatory update in November 2025, jointly revising the "Child-Resistant Packaging Guide for Pesticide Registration" with the U.S. Environmental Protection Agency (EPA) to significantly strengthenchild-resistant (CR) packaging standards for tinplate containers holding hazardous substances. The new rule mandates that tinplate packaging for cannabis, pharmaceuticals, chemicals, and other categories must pass 100% child-resistant testing. Enterprises concerned must complete packaging upgrades for all product lines by June 1, 2026, to comply with federal regulatory requirements, with non-compliant products facing severe penalties such as recalls and heavy fines.
Key Highlights of the New Regulation
This regulatory upgrade amends the 16 CFR §1700 series regulations under the Poison Prevention Packaging Act (PPPA), optimizing testing and compliance requirements for the metallic properties of tinplate packaging. The core content covers three major aspects:
● Strengthened Testing Standards: The child-resistance failure rate requirement for CR packaging is raised from the current 85% to 100%. Testing is conducted on children aged 42-51 months, and all participating children must be unable to open the package within the specified time under standard testing protocols. Meanwhile, the adult-friendliness requirement is retained—more than 90% of adults must be able to open the package within 5 minutes and properly re-secure it within 1 minute.
● Expanded Scope of Application: For the first time at the federal level, medical and adult-use cannabis products are included in mandatory CR packaging regulations for tinplate containers, unifying cross-state compliance standards. It also reaffirms that tinplate packaging for prescription drugs, over-the-counter drugs, household chemicals, pesticides, and other existing categories must meet the new standards simultaneously. The default exemption for metal containers is revoked, with case-by-case exemption applications only available for products that truly require metal packaging to ensure content stability.
● Enhanced Coordinated Enforcement: The EPA simultaneously updated pesticide packaging specifications, clarifying that tinplate packaging for pesticides must strictly comply with CPSC's new testing standards (refer to 40 CFR 157 Subpart B). Products failing to meet the standards will be ineligible for registration or renewal, forming a coordinated regulatory closed loop between the CPSC and EPA.
Compliance Timeline and Industry Impact
The CPSC has reserved a 6-month transition period for enterprises, specifying key timelines: November 2025 to January 2026 is the policy consultation period, during which enterprises can submit compliance inquiries and exemption applications; third-party testing institutions will start accepting new standard tests from January 1, 2026; the new rule will take effect on June 1, 2026, and products failing to complete packaging upgrades and testing certification will be banned from circulation in the U.S. market; the CPSC will launch full-scale enforcement from December 1, 2026, with non-compliant enterprises facing civil fines of up to $100,000 per day, mandatory product recalls, and criminal liability for serious violations.
For the tinplate packaging industry, short-term costs such as packaging design upgrades and third-party testing are expected, with packaging costs for related products rising by 5%-8%. However, in the long run, the new rule will drive technological iteration in the industry, with new CR structures such as double-locking and push-and-turn becoming mainstream. Meanwhile, the unified federal standard will reduce compliance costs for enterprises engaged in cross-state sales, particularly benefiting the standardized development of regulated industries such as cannabis and pesticides.
Recommendations for Enterprise Compliance
The CPSC and EPA jointly advise relevant enterprises to initiate compliance preparations immediately, with core actions including: assessing the gap between existing tinplate packaging designs and the new standards, prioritizing certified CR structure solutions; contacting qualified third-party institutions to complete testing and certification in advance in accordance with the 16 CFR §1700.20 testing protocol; collaborating with the supply chain to optimize production processes to ensure packaging materials and craftsmanship meet durability and compatibility requirements; and retaining test reports, certification documents, and other materials for inspection by regulatory authorities.
(Sources: U.S. Consumer Product Safety Commission (CPSC) November 2025 Announcement, U.S. Environmental Protection Agency (EPA) "Child-Resistant Packaging Guide for Pesticide Registration)
Post time: Jan-19-2026
