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Food for Thought
March 2023
Welcome to 'Food for Thought', a newsletter sharing key updates on food contact material (FCM) policy, ideas for revised FCM legislation and useful resources. There are thousands of chemicals in food contact materials that can potentially migrate into our food or drink, and many of these chemicals can harm our health and pollute the environment. This is why we need more protective regulation.

PFAS - they’re harmful for our health, persistent, and in our food packaging

PFAS are coming under increasing scrutiny – for their widespread contamination of people and the environment, their links with serious health conditions, and their widespread use in our lives including in food contact materials (FCMs).

Over 100 civil society organisations from across Europe are urging EU Member States and the Commission to ban all PFAS in consumer products, including FCMs, by 2025, and to have a complete ban by 2030.

In January, Denmark, Germany, the Netherlands, Norway and Sweden submitted a proposal to restrict PFAS under REACH to the European Chemicals Agency (ECHA). The public consultation on the proposal opened for comments on 22nd March, and will end on 25th September.

What are PFAS?

PFAS (per- and polyfluorinated alkyl substances) are a large family of thousands of human-made substances. Since their introduction in the late 1940s they have been increasingly used in a wide range of products and industrial applications – including food packaging, where they are often used for their capacity to repel both grease and water.

They have polluted our environment at an alarming scale and are accumulating in our bodies. The most studied PFAS have been linked to a range of negative health impacts – from thyroid disease to an increased risk of breast, kidney and testicular cancer. There is also growing evidence suggesting PFAS impact our fertility and globally obstetricians are calling for their removal to protect pregnant women and their developing babies. In 2019, the annual total health impact costs from PFAS exposure for the European Economic Area was estimated to be between €52 and €84 billion.

New study shows widespread PFAS pollution across Europe

A new cross-border study has shone the spotlight on widespread PFAS pollution across Europe. 

The Forever Pollution Project, conducted by 18 European newsrooms, identified over 17,000 sites that are known to be contaminated with PFAS. A further 21,000 sites are presumed to be contaminated. The chemicals had been detected in water, soil and living organisms. The highest levels of PFAS identified were in ground water around a production site in Belgium - residents within 15 km (10 miles) of the site have been told not to eat eggs or vegetables produced in their own gardens.

The project produced the first interactive map illustrating the widespread contamination of Europe with PFAS.

PFAS found in food packaging across Europe

Studies have found PFAS in food packaging and other food contact materials across Europe. 

A 2021 study from 8 civil society organisations (including Arnika, CHEM Trust and the Health and Environment Alliance – HEAL) found PFAS in disposable food packaging from popular fast-food chains, takeaway restaurants and supermarkets from across Europe. All 42 items tested had measurable levels of PFAS, including 32 samples that had been intentionally treated with PFAS. The highest concentrations were consistently found in items that were advertised as biodegradable or compostable.

Tests by consumer organisations in Italy, Denmark, Spain and France found that food contact materials that were intended to be alternatives to plastics, such as moulded fibre tableware and paper straws, contained PFAS. Some of the samples claimed to be compostable or biodegradable, but the presence of the highly persistent PFAS contradicts this claim.

Tests by European consumer organisations found that fast food packaging bought in Belgium, Denmark, Italy and Portugal was contaminated with PFAS.

PFAS restriction proposal highlights Food Contact Materials as area for substitution

In February, the European Chemicals Agency (ECHA) published the long-awaited PFAS restriction proposal. The proposal was prepared by authorities in Denmark, Germany, the Netherlands, Norway and Sweden, and has already been branded as the most significant and expansive restriction dossier in EU history.

The widespread, intentional use of PFAS in food contact materials (FCMs) including in packaging and processing equipment is known to be a direct exposure route for humans via chemical migration. The future ban of PFAS - the 'forever chemicals' - is therefore very relevant for FCMs.

The proposal recognised that all uses of PFAS in food contact materials have "high substitution potential at entry into force" (i.e. can be replaced within the 18 month transition period) and recommends restrictions of these chemicals in packaging of food and feed products, as well as food contact materials for use in consumer articles. The exception is the use of fluoropolymers and perfluoropolyethers in "industrial food and feed production" for which a time-limited derogation is proposed.

Denmark's success story

Denmark has already taken steps to address the use of PFAS in FCMs, and has demonstrated that where regulation has been put in place, it has effectively incentivized companies to move away from using PFAS.

From July 2020 onwards, cardboard and paper food contact materials in Denmark have not been allowed to be intentionally treated with PFAS, except for FCMs with a functional barrier that prevents migration of the substances into food. A 2021 study conducted by civil society organisations tested McDonald's french fries bags bought in Denmark, the Czech Republic, and the UK. The results found that PFAS had been intentionally used in the items bought in the Czech Republic and the UK. In comparison, none of the bags bought in Denmark exhibited PFAS treatment. This shows that legislation can and does protect people from exposure to harmful chemicals.

In January, France released the country's first action plan (link in French) specifically dedicated to PFAS. The plan acknowledges the severe consequences that PFAS have on people's health and the environment, and the urgent need to reduce production. Read more about the plan in this article from the Health and Environment Alliance (HEAL).

Health and environment groups hand Ban PFAS manifesto to EU Commission

On 14 March, health and environment groups representing 119 civil society organisations from all over Europe presented the Ban PFAS manifesto to the cabinets of European Commission Vice President Timmermans and Environment Commissioner Sinkevičius. The manifesto calls for the ban of PFAS in consumer products by 2025 and a complete ban by 2030.

This newsletter is produced by a collaboration between CHEM Trust, the Health and Environment Alliance (HEAL) and Zero Waste Europe (ZWE). Together, we are working towards creating a toxic-free environment where nobody should have to worry about the presence of health-harming chemicals in the products that come into contact with our food.

CHEM Trust is a charity based in Germany and the UK, with the overarching aim to prevent synthetic chemicals from causing long term damage to wildlife or humans, by ensuring that chemicals which cause such harm are substituted with safer alternatives. (EU Transparency number: 27053044762-72)

The Health and Environment Alliance (HEAL) is the leading not-for-profit organisation addressing how the environment affects human health in the European Union (EU) and beyond. HEAL works to shape laws and policies that promote planetary and human health and protect those most affected by pollution, and raise awareness on the benefits of environmental action for health. (EU Transparency number: 00723343929-96)

Zero Waste Europe (ZWE) is the European network of communities, local leaders, experts, and change agents working towards the elimination of waste in our society. We advocate for sustainable systems and the redesign of our relationship with resources, to accelerate a just transition towards zero waste for the benefit of people and the planet. (EU Transparency number: 47806848200-34)
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