UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION III

1650 Arch Street

Philadelphia, Pennsylvania 19103

DATE: August 5, 2010

SUBJECT: Technical Support Document for Maryland’s Adoption of Control 

Techniques Guidelines for Flexible Packaging Printing 

/s/

FROM: Irene Shandruk, Physical Scientist 

Office of Air Program Planning 

TO: File

/s/

THRU: Maria A. Pino, Acting Associate Director 

Office of Air Program Planning

A. BACKGROUND 

What is the flexible package printing CTG?

Section 172(c)(1) of the Clean Air Act (CAA) provides that state implementation plans 

(SIPs) for nonattainment areas must include reasonably available control measures

(RACM), including reasonably available control technology (RACT), for sources of 

emissions. Section 182(b)(2)(A) provides that for certain nonattainment areas, States 

must revise their SIPs to include RACT for sources of volatile organic compound (VOC)

emissions covered by a control techniques guidelines (CTG) document issued after 

November 15, 1990 and prior to the area’s date of attainment. 

The United States Environmental Protection Agency (EPA) defines RACT as “the lowest 

emission limitation that a particular source is capable of meeting by the application of 

control technology that is reasonably available considering technological and economic

feasibility.” (44 FR 53761, Sept. 17, 1979). In subsequent Federal Register notices, EPA 

has addressed how states can meet the RACT requirements of the CAA. 

The CTG for flexible package printing is intended to provide state and local air pollution 

control authorities information that should assist them in determining RACT for VOCs

from flexible package printing facilities. In developing this CTG, EPA, among other 

things, evaluated the sources of VOC emissions from this industry and the available 

control approaches for addressing these emissions, including the costs of such 

approaches. Based on available information and data, EPA provides recommendations 

for RACT for VOCs from flexible package printing facilities.
In December 1978, EPA published a CTG for graphic arts (rotogravure printing and 

flexographic printing) that included flexible package printing.1The 1978 CTG discusses 

the flexible package printing industry, the nature of VOC emissions from that industry, 

available control technologies for addressing such emissions, the costs of available 

control options, and other items. 

EPA also published a national emission standard for hazardous air pollutants (NESHAP) 

for the printing and publishing industry (40 CFR Part 60, Subpart KK) in May 1996, 

which is applicable to flexible package printing.

In September 2006, after conducting a review of currently existing state and local VOC 

emission reduction approaches for flexible package printing, reviewing the 1978 CTG 

and the 1996 NESHAP for the printing and publishing industry (40 CFR Part 60, Subpart 

KK), and taking into account the information that has become available since then, EPA 

developed a new CTG for flexible package printing entitled Control Techniques 

Guidelines for Flexible Package Printing (Publication No. EPA 453/R-06-003). 

What is flexible packaging?

Flexible packaging refers to any package or part of a package, the shape of which can be 

readily changed. Flexible packaging includes, but is not limited to, bags, pouches, liners, 

and wraps utilizing paper, plastic, film, aluminum foil, metalized or coated paper or film, 

or any combination of these materials. Flexible package manufacturers are sometimes 

referred to as "converters." The word "converted" in this use is an industry-specific term 

that refers to the fact that flexible packaging materials start out as rolls of paper or foil, or 

beads of plastic resin, and are "converted" into a package or roll of packaging material. 

Printing on flexible packaging is almost entirely conducted by rotogravure and wide-web 

flexographic printing.

Printing, coating, and laminating may all be performed on or in-line with a flexible 

package printing press; and these activities are included in the source category. One 

portion of the flexible packaging industry provides fully printed packaging materials 

(designated "preformed specialty bags") to contract packagers. Another portion provides 

combination or laminated materials (designated converted wrap) for printing and/or final 

packing by captive packaging operations. Applying coatings is a major capability of 

flexible packaging converters. So, the same facilities may be used to manufacture nonpackaging materials such as gift wraps and hot stamp foils. The industry makes a 

distinction between labels and wrappers, which are package components, and a product 

that becomes the entire package and should be called a flexible package. Any printing of 

shrink-wrap labels or wrappers conducted on or in-line with a flexible package printing 

press is also considered to be included under the flexible packaging source category. 

Printing of self-adhesive labels would not be considered flexible packaging.

 

1 Control of Volatile Organic Emissions from Existing Stationary Sources—Volume VIII: Graphic Arts—

Rotogravure and Flexography. EPA Publication No. EPA-450/2-78-033. U.S. Environmental Protection 

Agency. Research Triangle Park, NC. December 1978.
Rigid packaging printing operations are often co-located with flexible package printing 

operations. Folding cartons, some labels and wrappers, gift wraps, wall coverings, vinyl 

products, decorative laminates, floor coverings, tissue products, and miscellaneous 

specialty products are not considered flexible packaging.

There are two types of printing processes used by flexible package printing facilities: (1) 

rotogravure printing; and (2) flexographic printing. And there are two main sources of 

VOC emissions from flexible package printing for both rotogravure and flexographic: (1) 

evaporation of VOC from inks, coatings, and adhesives, and (2) evaporation of VOCs

from cleaning materials.

There are two approaches to reducing VOC emissions from inks, coatings, and adhesives 

used in the flexible package printing industry: (1) adding/improving add-on controls, and 

(2) material reformulation or substitution. The first approach includes improving capture 

and/or control systems or adding control systems where none are in use. Capture and 

control can be addressed separately, although in many cases, improved capture is 

achieved through an increase in the amount of air handled and can necessitate up-grades 

to existing control devices. The second approach, focusing on pollution prevention, is to 

substitute low VOC or VOC-free materials for materials (inks, coatings, and adhesives) 

presently in use.

EPA’s Recommended Control Options for Flexible Package Printing

EPA issued a CTG for Flexible Packaging Printing on September 2006 (EPA 453/R-06-

003). Recommendations for controlling VOC emissions from inks, coatings, adhesives 

and cleaning materials used in flexible package printing operations are outlined in the 

CTG and are as follows: 

A. Coatings, inks and adhesives used on flexible package printing presses:

The recommended level of control for VOC emissions from coatings, inks and 

adhesives used on flexible package printing presses is tied to the first installation date 

of the equipment. The first installation date for a piece of equipment does not change 

if the equipment is later moved to a new location. For example, a brand new press 

first installed in 1992 is moved to a new location in 1998 – the first installation date 

for this press is still 1992. Or, if a brand new control device first installed in 2004 is 

moved to a new location in 2009 – the first installation date for this control device is 

still 2004. The first installation date for a control device does not change if it is later 

used to control a new press. For example, if a brand new press is installed in 2009 

and emissions from this press are controlled by a control device that was first 

installed in 2002, then the first installation date for this press is 2009 and the first 

installation date for this control device is still 2002. 

 The recommended control levels in EPA’s final CTG include the following: 

• 65 percent overall control for a press that was first installed prior to March 

14, 1995 and that is controlled by an add-on air pollution control device 
(APCD) whose first installation date was prior to the effective date of the 

State RACT rule. 

• 70 percent overall control for a press that was first installed prior to March 

14, 1995 and that is controlled by an add-on APCD whose first installation 

date was on or after the effective date of the State RACT rule. 

• 75 percent overall control for a press that was first installed on or after 

March 14, 1995 and that is controlled by an add-on APCD whose first 

installation date was prior to the effective date of the State RACT rule. 

• 80 percent overall control for a press that was first installed on or after 

March 14, 1995 and that is controlled by an add-on APCD whose first 

installation date was on or after the effective date of the State RACT rule. 

As an alternative to emission reduction percentages specified above, EPA also 

recommends providing the following two equivalent VOC content limits which can 

be met by use of low VOC content materials or combinations of materials and 

controls as follows: (1) 0.8 kg VOC/kg solids applied, or (2) 0.16 kg VOC/kg 

materials applied. These VOC content limits are consistent with an 80 percent overall 

emissions reduction level and reflect similar control levels as the capture and control 

option. The VOC content limits can be met by averaging the VOC content of 

materials used on a single press, i.e., within a line.

B. Cleaning Materials Work Practices at Flexible Package Printing Presses: 

Recommended work practices for cleaning materials are to keep cleaning 

materials and used shop towels in closed containers, and convey cleaning 

materials from one location to another in closed containers or pipes.

B. STATE SUBMITTAL

On April 23, 2010, Maryland Department of the Environment (MDE) submitted to EPA a 

SIP revision concerning the adoption of the EPA CTG for flexible packaging printing. 

EPA develops CTGs as guidance on control requirements for source categories. States 

can follow the CTGs or adopt more restrictive standards. MDE is adopting EPA’s CTG 

standards for flexible packaging printing and work practices (see EPA 453/R-06-003, 

September 2006). This SIP revision includes amendments to Regulation .10 and a new 

regulation .10-1 under COMAR 26.11.19, Volatile Organic Compounds from Specific 

Processes. This action affects sources that use flexographic and rotogravure presses to 

print flexible packaging materials. 

COMAR 26.11.19.10 – Flexographic and Rotogravure Printing is amended as follows to 

include language pertaining to flexible packing printing:

Section .10(B)(2): The provisions of this regulation (ie. COMAR 26.11.19.10) do 

not apply to printing on fabric, metal, plastic, or to flexible package printing 

subject to COMAR 26.11.19.10-1.

Section .10(C)(1): A person who owns or operates a printing press that uses 

flexographic, packaging rotogravure, or publication rotogravure methods and is a 
major stationary source shall reduce emissions by using water-based inks that 

contain less than 25 percent VOC by volume of the volatile portion of the ink, or 

high solids inks that contain not less than 60 percent by weight nonvolatiles.

COMAR 26.11.19.10-1 – Flexible Packaging Printing is being added:

Section .10-1(A): Includes definitions for flexible packaging, flexible packaging 

coatings, flexible packaging printing, and flexible packaging printing line.

Section .10-1(B): Describes the applicability of this regulation.

Section .10-1(C): Describes emission standards and requirements for major 

stationary sources that perform flexible packaging printing. 

Section .10-1(C)(1): Emissions are either reduced by using water-based 

inks that contain less than 25 percent VOC by volume of the volatile 

portion of the ink, or high solids inks that contain not less than 60 percent 

nonvolatiles. 

Section .10-1(C)(2): If compliance cannot be achieved through use of the 

water-based inks or high solids inks described above in (C)(1), the source 

shall reduce the VOC content of each ink, or reduce the average VOC 

content of inks used at each press as follows:

(a) 60 percent reduction for flexographic presses;

(b) 65 percent reduction for packaging rotogravure presses; and

(c) 75 percent reduction for publication rotogravure presses.

Section .10-1(D): Describes additional emission standards and requirements for a 

person who owns or operates a flexible packaging printing line with potential to 

emit VOCs of 25 tons or more per year. Compliance is met by:

Section .10-1(D)(1): Limiting the VOC content of each flexible 

packaging coating or limiting the average VOC content of flexible 

packaging coatings of the line to not more than:

(a) 0.8 lb VOC/lb or kg VOC/kg solids applied; or

(b) 0.16 lb VOC/lb or kg VOC/kg materials applied; or by that 

described in Section .10-1(D)(2).

Section .10-1(D)(2): Venting the dryer exhaust of the line through a 

control device that is constructed, operated, and maintained to achieve an

overall control efficiency of:

(a) 65 percent overall control for a press that was first installed prior 

to March 14, 1995 and that is controlled by an add-on APCD 

whose first installation date was prior to the effective date.

(b) 70 percent overall control for a press that was first installed prior 

to March 14, 1995 and that is controlled by an add-on APCD 

whose first installation date was on or after the effective date of the 

rule.

(c) 75 percent overall control for a press that was first installed on or 

after March 14, 1995 and that is controlled by an add-on APCD 

whose first installation date was prior to the effective date of the 

rule.

(d) 80 percent overall control for a press that was first installed on or 

after March 14, 1995 and that is controlled by an add-on APCD 
whose first installation date was on or after the effective date of the 

rule.

C. EPA EVALUATION

The State of Maryland has adopted the standards and requirements of the CTG for 

flexible packaging printing and is amending its SIP to reflect these amendments. The 

maximum benefit from these amendments will be provided during the ozone season when 

VOCs readily combine with NOx to form ground-level ozone. Therefore, this revision 

will help Maryland attain and maintain the NAAQS for ozone. 

D. CONCLUSIONS AND RECOMMENDED AGENCY ACTION

The adoption of the EPA CTG requirements for flexible packaging printing by the State 

of Maryland will result in the reduction of VOC emissions from flexible packaging 

printing. EPA approval of the SIP revision is recommended