Key chemicals of concern in food packaging and food handling equipment

Notes:

• Ortho-phthalates: FDA is currently reviewing petitions to revoke their uses. Maine banned sale of food packaging (printing materials, inks, pigments, adhesives, stabilizers, coatings, plasticizers, etc.) containing phthalates effective January 1, 2022. Testing of recycled plastics has revealed presence of phthalates.
• PFAS: FDA banned use of long-chain PFAS in 2016 but illegal uses may continue. In 2020 FDA announced that four chemical manufacturers were voluntarily phasing out 6:2 fluorotelomer alcohol, a short-chain PFAS, from certain paper packaging intended for food contact (i.e. greaseproof paper). In 2021, EPA testing revealed that certain PFAS (perfluoroalkyl carboxylic acids) can form and migrate from fluorinated polyethylene containers. PFAS may be migrating into food via fluorinated plastic containers not authorized by FDA for food contact use. The state of Washington, concerned that paper and cardboard food packaging treated with PFAS may be contaminating composting and paper recycling processes post-consumer, conducted a safer alternatives assessment and prohibited PFAS use in four food packaging categories effective early 2023. California, Connecticut, Maine, Minnesota, New York and Vermont also have banned PFAS use in certain food packaging.
• Perchlorate: Young children’s exposure to perchlorate increased after FDA’s approval of perchlorate for use as a food contact substance in 2005. Perchlorate exposure can pose a risk to a child’s healthy development. In April 2019 FDA reaffirmed their decision to continue to allow the use of perchlorate in plastic packaging and processing equipment and denied requests for public hearings on the matter.
• Benzophenone: In Oct. 2018, FDA banned synthetic benzophenone from use as a flavor and in food packaging effective Oct. 2020.
• Starred (*) chemicals are also recommended for minimization or phase out in “Food Packaging Product Stewardship Considerations,” a set of best practices released in 2018 by the Food Safety Alliance for Packaging, a part of the Institute of Packaging Professionals, to reduce problematic chemicals in food packaging.

Notes:

• Bisphenol compounds: FDA banned BPA use in baby bottles and as a coating of infant formula packaging based on abandoned uses. BPS became a common replacement to BPA in packaging, but studies demonstrate similar health concerns to BPA. In December 2021, the European Food Safety Authority released a draft opinion recommending a safe daily intake of BPA more than 5000 times lower than the average daily intake of BPA estimated by FDA. In January 2022, advocacy groups including EDF petitioned FDA to remove approvals of BPA use as a food additive.
• NMP: Banned by EPA in paint strippers sold for non-commercial use.
• Starred (*) chemicals are also recommended for minimization or phase out in “Food Packaging Product Stewardship Considerations,” a set of best practices released in 2018 by the Food Safety Alliance for Packaging, a part of the Institute of Packaging Professionals, to reduce problematic chemicals in food packaging.

Notes:

• Heavy metals: 19 states have banned their intentional use and set a 100 ppm limit for total concentration of lead, cadmium, chromium and mercury in packaging and components. Heavy metals shown to cause harm at very low-level exposures can result in significant toxicity, and some can build up in the body. FDA’s Toxic Elements Working Group, whose mission in part is to develop a strategy to prioritize and modernize activities with respect to food/toxic element combinations, is focused on children’s exposure. In 2020, FDA announced its Closer to Zero Action Plan for reducing exposure to toxic elements, particularly arsenic, lead, cadmium and mercury, from foods for babies and young children.
• Starred (*) chemicals are also recommended for minimization or phase out in “Food Packaging Product Stewardship Considerations,” a set of best practices released in 2018 by the Food Safety Alliance for Packaging, a part of the Institute of Packaging Professionals, to reduce problematic chemicals in food packaging.