Q&A

Forever... For Now, Part III: How A Potential Ban on PFAS Could Impact Food and the Food Packaging Industry

The European Union's potential ban on the production, import, and sale of PFAS, a.k.a. "Forever Chemicals", could impact various industries worldwide. A final ruling on the ban is expected in Q4 of 2023.

In this Q&A, we're focusing on food and the food packaging industry.

Specifically, we'll address:

How and why are PFAS used in food packaging, along with the known risks.
Unique challenges and supply chain concerns that the food packaging industry and their customers – food companies, restaurants, and consumers -- will face if a European ban on PFAS is enacted.
Solutions to avoid potential compliance issues and liabilities associated with PFAS.

To learn more about the history, uses, health risks, and environmental impacts of forever chemicals, as well as emerging regulations aimed at banning them, please read our comprehensive PFAS overview, "Forever...For now".

What are PFAS?

PFAS stands for "per- and polyfluoroalkane substances", also known as "forever chemicals". There are over 10,000 different kinds. These chemicals are incredibly stable due to the strong carbon-fluorine bond and last longer in the environment than any other known type of synthetic chemical. We don't have any way (yet) of breaking down these chemicals so in practical terms they really are "forever". PFAS are known to be toxic for reproduction and can cause damage to unborn children. They have also been linked to certain cancers, reduced vaccine efficacy in children, and liver problems, among others.

Why have products containing PFAS become vital, if not necessary, in the food and food packaging industry?

One big reason is consumer demand. In the United States and Canada, there's been a push from consumers, and lawmakers, for packaging that is not made from single-use plastic. In Canada, recent regulations mandated phasing-out single-use plastics altogether. The push against plastics eventually led to an industry shift in the late 2000s toward making and using more sustainable packaging made from paper, cardboard, and compostable materials. However, many of these non-plastics, including those marketed as compostable, have since been found to contain PFAS, mainly because they needed to be "liquid proof" to effectively replace plastics as food packaging. This is referred to as a "regrettable substitution," which we'll cover further below.

How are PFAS used in the food and food packaging industry?

PFAS are used to make materials liquid-proof. In food packaging applications, they prevent liquids, grease, and fats from transferring through paper and cardboard. Think microwave popcorn bags, pizza boxes, paper-like boxes and bowls for takeout, as well as paper packets and wrappers used for fast food and pastries. PFAS have been found to migrate from the packaging to food, and studies indicate they're more likely to migrate if the food is fatty, salty, and/or acidic.

PFAS have also been found in plastic bottles, including plastic bottles containing fruit juices. This is most likely due to PFAS-based lubricants being used on machinery during manufacturing. Another potential source is a process called "direct fluorination", which is used to treat certain plastics.

How prevalent are PFAS in the food and food packaging industry?

PFAS are so widely used – from the lubricant on the machines that make the packaging to the ink that goes on the packing -- that it is sometimes difficult to ascertain when, how, or why they were added. (That kind of detective work falls outside of normal business operations for most companies. Therefore, it becomes essential to work with outside experts who've modeled their business around solving these problems -- with accuracy and efficiency at lower cost than trying to perform the work in-house.

Nonetheless, their prevalence amongst food and food-packaging is widespread; they can be found in every type of restaurant, from fast-food to health food, and in every type of grocery store, from budget to high-end.

PFAS have also been found in pet food packaging and been detected in commonly used food pesticides (though the amount of PFAS from those pesticides that reaches the consumer is not yet clear). PFAS are sometimes deliberately added to pesticides but can also get into them accidentally.

What is "Regrettable Substitution?"

Regrettable substitution is an issue in every industry -- food packaging is no exception. It happens when a banned chemical or material is replaced with yet another harmful chemical or material. This can happen for a multitude of reasons. Often, it's due to a lack of knowledge about a chemical's risks and dangers.

The replacement of bisphenol A (BPAs) in plastics with similarly harmful chemicals is a well-known example of regrettable substitution.

Switching from single-use plastic to sustainable packaging with PFAS, mentioned earlier, is another. Known as fluorotelomers (a.k.a. 6:2 FTOH), that group of PFAS were considered at the time to be safe for consumers. However, by 2020, as more data had become available, the FDA raised concerns and a voluntary industry phase-out of fluorotelomers was announced in the U.S.

Given our experience in chemical substitution projects, working with an expert partner like Actalent is an effective strategy for reducing the risk of regrettable substitution.

What are the risks associated with PFAS in food packaging?

Put simply, everyone eats food. Thus, compared to other products that contain PFAS, a wider range of consumers are likely to encounter PFAS via food packaging. The risk of exposure occurs when PFAS migrate from the food packaging to the food itself, which is then ingested. The likelihood of migration and the risk level depends on the level of PFAS in the packaging and the type of food it contains. And because PFAS are generally not deliberately added to the food itself, consumers are also not likely to be informed if products contain PFAS. Yet, as studies and media coverage expand, more and more people are becoming aware of PFAS and their use in food packaging. And, in the eyes of the public and lawmakers, if the risk of using PFAS outweighs the environmental benefit (some question if there is a benefit, since PFAS in compostable materials don't actually break down and migrate into water sources) then significant restrictions, like those proposed in Europe, could follow.

What unique challenges does the food packaging industry face when it comes to PFAS?

A ban on PFAS in the European Union would have significant impacts beyond the EU. Much like automakers build U.S. vehicles to comply with California Emissions Standards, regardless of what state they're sold in, manufacturers and suppliers of food packaging products and materials for the EU could stop using PFAS altogether, not just in the products they make for Europe. In that scenario, the food packaging products end-users have been buying, in and outside of the EU, could stop being available in their current form. The supply, price, design, and quality could all change.

Another sign of change: 3M, a mass producer of PFAS, has committed to stop making them by 2025. That means even if bans don't occur, 3M's decision will significantly reduce the supply and availability of PFAS in the market. Furthermore, any companies looking to fill 3M's void would likely face the same type of liability exposures that led 3M to abandon PFAS in the first place.

Another challenge: the food packaging industry is more highly regulated than many other industries. Thus, any alternatives must still comply with existing regulations.

Another consideration: food costs. Consumers are already frustrated with rising prices. Any further increase passed on due to higher packaging costs will likely cause them to seek less expensive options. The same is true for restaurants, where margins are razor thin. So, if food and packaging manufacturers are mandated to stop using or making PFAS packaging, they will have to be highly strategic in how they approach implementing substitutes. It's often easy to overlook a viable, cost-effective approach in favor of an easier, but more expensive one. Companies could lose customers if their competitors are making safe, quality substitutes at a lower cost than them.

How is Actalent uniquely placed to partner with companies in the food and food packaging industry?

The breadth and depth of our expertise is how we help companies find safe, effective substitutes for banned chemicals. We have chemical and materials engineers that can identify banned chemicals in the largest product lines and most complex supply chains. We have systems, software, and database experts that can gather, capture, harness, and interface valuable product and materials data. We have mechanical engineers that can design, model, and validate safer yet effective packaging. We have manufacturing engineers that can design and implement new processes and, if needed, new equipment layouts. And our collective regulatory expertise will ensure your materials and processes are safe and in-compliance throughout the life cycle of your products. That includes success in food and food packaging.