Sustainability: Position Statements

Position Statements

TLMI Position on Climate Change

TLMI recognizes the risks posed by global climate change, such as more severe weather events and adverse impacts on human health and the environment; therefore we encourage TLMI members to take significant action to reduce greenhouse gas (GHG) emissions.


TLMI staff and committees have undertaken numerous efforts to promote and provide opportunities to reduce and recycle business waste which provides opportunities for companies to reduce GHG emissions. TLMI also supports the Sustainable Green Printing Partnership, a third-party audited certification program which enables our members to create a Sustainability Management System for tracking and improving environmental impacts, including GHG emissions.


It is TLMI’s position to:


  • Continue our efforts to encourage members to voluntarily reduce GHG emissions.
  • Actively partner with other organizations that can assist members in reducing GHG emissions in manufacturing and in the supply chain.
  • Engage with stakeholders to explore markets for environmentally preferable products.

TLMI believes that voluntary measures offer the greatest opportunity for our members to design innovative solutions that work best for their own companies and products; however, tackling climate change will require action from all parties in all sectors.


TLMI supports legislative and regulatory policies that promote low carbon and renewable energy projects and offer incentives for energy efficiency improvements, renewable energy implementation, and enable companies to strategically plan for long-term energy alternatives. TLMI also supports the establishment of emissions reduction targets guided by the best available science and technology, and providing credits for companies that have achieved verifiable voluntary emissions reductions.

TLMI Position Statement on Sustainable Consumption and Production

TLMI believes that industries, businesses, and consumers must move toward more sustainable patterns of consumption and production. A key way to do this is to reduce the amount of waste generated, use materials that are sustainably sourced and have minimized impact on the planet, and follow the waste management hierarchy as a guide for end of life management.


For TLMI members, this includes:


  • Optimizing the use of label materials

  • Source reduction: redesigning products to use fewer materials

  • Giving preference to materials that are designed for reuse or recycling or enable the reuse or recycling of a package

  • Giving preference to materials that contain recycled content

  • Recycling materials into their highest possible use and avoiding downcycling

  • Seeking non-landfill end-of-life options for non-recyclable manufacturing waste

  • Reducing unnecessary packaging

TLMI Position on Tariffs

In 2017, the Office of the United States Trade Representative (USTR) began to review US imports, focusing on potential national security threats and technology/software theft. As part of this review, Administration officials examined opportunities to increase domestic manufacturing and jobs. USTR considers tariffs as one pathway to achieving increased domestic manufacturing, output and associated jobs.


USTR’s review of imports, exports and their economic impact resulted in the issuance of tariffs ranging from 10-25 percent on a broad range of raw materials and products from China, the European Union, Canada, Mexico and other countries. The most significant of these tariffs for TLMI member companies was for 10 percent, levied on $200 billion worth of products imported from China. These tariffs became effective in September of 2018.


The 2018 tariffs have had a significant impact across labels, tags, packaging, adhesives, paper and film substrates, equipment and other products utilized within the. Compounding these challenges are retaliatory tariffs that have been issued in response by China, the European Union and other countries.


Several TLMI member companies filed tariff exclusion requests and sought product reclassifications to avoid additional product and raw materials cost. Overall, very few exemption requests have been granted by the agency.


TLMI Position Statement:


  • It is imperative that the economic playing field is level across the globe for all manufacturers.

  • Implementation of broad-based tariffs has added to the cost and availability of many products and raw materials throughout the tag and label industry supply chains.

  • Tariffs should be individual, product-specific and justified with the effects to US manufacturing well understood.

  • TLMI opposes arbitrary and undefined tariff rate schedule increases for imported products.

  • USTR should ensure “due process” is made available for all stakeholders.

    • Due process should include, but not be limited to:

      • Justification as to why an exclusion request is either granted or denied

      • Appropriate documentation supporting any decision by USTR

      • A clearly outlined appeals process for stakeholders.

  • USTR should allow “consolidated industry or organization exclusion requests”, rather than requiring an individual or company provide the request for a tariff exclusion.

TLMI Position Statement on Ensuring Printed Labeling Options

In an increasingly digital world, printed labeling and information options, which provide instructions, guidance and warnings, remain critically important for consumers. Approximately 30% of all Americans, roughly 90 million people, remain without consistent access to Wi-Fi or similar Internet services and technology. Natural and other disasters can also cut off access to existing technology for long periods of time.


Several federal government agencies have relaxed or rescinded printed labeling information and mailing requirements over the past few years. Some of these changes to digital or electronic format include delivery of financial reports, tax forms, notice of tax filing options and Social Security statements.


Beyond these relaxed printed paper regulatory requirements, some federal agencies are also transforming existing printed label information into an electronic format.


A recently issued final rule highlighting the presence of Bioengineered (BE) foods require simple QR codes for the consumer to scan with their smartphone to find additional product information. This rule not only reduces the amount of printed labeling required to be “on-product”, but also minimizes information provided to consumers without access to smartphone or similar technology.

The FDA has also considered for several years a move from required printed medicine and prescription drug information to delivery of information in a TBD electronic format


TLMI Position Statement:


  • TLMI recognizes that not all Americans have ready access to necessary product information through smartphones or similar online technology.

  • The information and format provided via printed labeling is an important element of consumer education and safety.

  • Electronic labeling has a role to play in accompanying rather than replacing traditional label and other paper-based information.

  • Printed labeling should remain mandatory in all areas where consumer or patient safety is at potential risk. Content via electronic format may also be offered in a complementary fashion.