Last year, PRINTING United Alliance informed our members of proposed legislation in New Jersey that sought to ban carbon black and other chemicals in packaging. This bill, part of a broader trend targeting certain materials over toxicity concerns, would have severely impacted the printing industry as it would have banned the use of black printing ink on covered packages. Carbon black is the pigment used to make black ink and plays a critical role in four-color process printing and labeling. A ban would have restricted critical product information, including instructions, warnings, and expiration dates, while also discouraging the use of recycled materials in packaging. The language of this bill was incorporated into NJ S3398, the Packaging Product Stewardship Act, which initially maintained the same concerns regarding carbon black restrictions on packaging.
Recognizing the significant impact of such a ban, the Alliance took direct action and joined a coalition of industry stakeholders to advocate against this legislation. This included submitting detailed comment letters to key legislators outlining the essential role of carbon black in printing and demonstrating that it does not pose a toxicity risk when bound in ink. Additionally, we engaged in multiple meetings with government officials to ensure they understood the unintended consequences of the proposed restrictions. Through the Alliance’s efforts, members of the coalition that testified against the bill included a description of how the ban would impact their ability to offer products for sale in the state.
As a result of this advocacy, the Alliance helped secure an exemption for printing ink in the revised legislation. Under the latest version of NJ S3398, carbon black is now permitted when used as a pigment in printing inks for packaging, labels, tags, or any related components. The final language reads:
(5) non-detectable pigments including carbon black, except when the pigment is used as a pigment in printing inks used to print on packaging, labels, tags, or any component thereof.
The Alliance engaged in similar efforts last year in New York, where proposed legislation included a ban for carbon black on packaging. Like in New Jersey, the Alliance took direct action and worked alongside industry partners, submitted formal comments, launched an action alert encouraging members to contact their representatives, and met with policymakers to advocate for the industry. While the bill ultimately passed the Senate, but failed to pass in the Assembly, carbon black had been removed from the final version. Furthermore, when a new version of the bill was introduced this year, it did not include any language targeting carbon black. This is a significant victory for the printing and packaging industry in New York.
The Alliance remains committed to monitoring the regulatory and legislative landscape to ensure that policies impacting the printing industry are grounded in science and practicality. As regulations continue to evolve, the Alliance strives to lead the industry through these changes, advocating for balanced policies that support both sustainability and business operations. Through proactive engagement, coalition-building, and informed advocacy, we will continue to work with policymakers and industry partners to shape a regulatory environment that fosters innovation and long-term success.
In this article, Sara Osorio, Coordinator, EHS Affairs, PRINTING United Alliance, provides an update to New Jersey’s proposed EPR legislation. More information about EPR legislation can be found at Business Excellence-EHS Affairs or reach out to Sara directly if you have questions about how these issues may affect your business: sosorio@printing.org.
To become a member of the Alliance and learn more about how our subject matter experts can assist your company with services and resources such as those mentioned in this article, please contact the Alliance membership team: 888-385-3588 / membership@printing.org.
