The end to forever chemicals in snack packaging?

In February 2024, the Food and Drug Administration (FDA) announced grease-proofing materials containing per- and polyfluorinated substances (PFAS), or forever chemicals, would no longer be used in new food packaging such as microwave popcorn bags, fast-food wrappers and takeout boxes sold to US consumers.

In a nod to progressing food chemical safety, eliminating PFAS signals the end to a “major source of dietary exposure to PFAS”, Jim Jones, deputy commissioner for Human Foods at the FDA, said in a statement.

With the FDA recognizing the move as an important milestone to protect US consumers from potentially harmful food-contact chemicals, pressure is growing for voluntary actions and further policy guidance in the wider sector.

“With the growing recognition of the problems PFAS cause from cancer to fertility issues, PFAS are facing increasing international scrutiny that businesses and governments need to adapt to,” Megan Kirton, project officer for environmental charity Fidra, told Bakery&Snacks.

In March 2024, research conducted by Swiss-based Food Packaging Forum found 68 PFAS in food packaging and only 39 of these complete with testing data to check for hazards. The majority of these PFAS were not detailed in regulatory or industry documents, signalling the need for more transparency, education and action.

Chemicals in snack packaging

Pic: GettyImages/Valeriy Lushchikov (Valeriy Lushchikov/Getty Images)

“Consumers cannot see whether a specific packaging releases harmful chemicals, such as forever chemicals PFAS, into foods,” Dr Birgit Geueke, senior scientific officer at the Food Packaging Forum Foundation, told this site.

“Even experts cannot see this without performing chemical analyses in a laboratory.”

Added Dorota Napierska, toxic-free circular economy policy officer at Zero Waste Europe, “It’s practically not possible to provide an exact number on the use of PFAS in different types of food packaging, as the manufacturers are not obliged to provide such information.

“But the use of PFAS has definitely been confirmed in certain segments.”

In particular, PFAS are found in paper-based packaging, microwave popcorn packs, and pizza boxes.

In recent years, some retailers and governments have addressed these PFAS in packaging and alternatives have become available.

“It’s unclear whether all microwave popcorn bags on the market are PFAS-free, but there is a realistic chance that responsible manufacturers replaced these chemicals with something else,” said Geueke.

For a sector dominated by chemical concerns in its packaging, the industry’s knowledge on actual PFAS prevalence throughout the baked goods and snack packaging sector remains unclear due to a lack of transparent processes.

Growing body of evidence suggests widespread PFAS use

Pic: GettyImages/Francesco Scatena (Francesco Scatena/Getty Images)

Research has uncovered the presence of PFAS in grease-proofed materials such as microwave popcorn bags. In December 2023, a study on single-use food packaging from 17 countries found that McDonald’s, KFC, Burger King, Subway, Starbucks, Dunkin’ Donuts, and Jolly Time use both PFAS-containing and PFAS-free packaging.

A 2021 European-wide investigation indicated the presence of PFAS in disposable food packaging and tableware used by popular fast-food chains and takeaway restaurants across Europe. All 42 analysed items had measurable levels of PFAS chemicals, with the highest PFAS concentrations consistently found in molded fiber products, such as bowls, plates and food boxes advertised as biodegradable or compostable disposable.

According to Fidra’s 2020 commissioned research, PFAS were found in packaging collected from eight out of nine major UK supermarkets and 100% of takeaways tested. Packaging that contained PFAS included supermarket cookie and bakery bags, molded fiber boxes and microwavable popcorn packaging.

“This is alarming because PFAS are highly persistent chemicals that take thousands of years to break down,” Kirton said.

A necessary feature in packaging or an adverse risk?

The EFSA states that PFAS are generally used when the industry seeks fat, oil or water repellency for a product. PFAS have been used in paper and board food packaging since the 1950s, primarily as a coating to prevent food-based fat and water from soaking in and reducing the material’s strength.

“This is a problem particularly associated with fatty foods and those intended to be heated in the packaging or stored for extended periods,” said Kirton.

The application of PFAS makes paper and cardboard packaging – such as fast food wrappers and pizza boxes – water and grease-repellent. PFAS may also enhance the material’s optical appearance and strength.

PFAS are used to provide stain resistance and water and oil repellency.

“Plain paper or cardboard packaging is insufficient to contain food due to poor barrier properties and therefore always combined with chemical additives, coated or laminated with aluminium or plastic to improve the packaging properties,” Napierska said.

“However, PFAS are certainly not essential in food packaging,” noted Kirton, adding there are numerous PFAS and plastic-free food packaging suppliers and many countries taking steps to phase out PFAS from this and other uses. Denmark, for example, has banned using PFAS in paper and card food contact materials since July 2020.

Available packaging alternatives

Pic: GettyImages/Oleksandr Hruts (Oleksandr Hruts/Getty Images)

“As this is an issue of public concern, it is known that the industry has been looking for alternatives,” an EFSA spokesperson told Bakery&Snacks.

Following its research, Fidra engaged with some of the UK’s biggest retailers, with many agreeing to reduce or remove intentionally added PFAS from their brand food packaging.

“However, to ensure all food packaging is free from harmful ‘forever chemicals’, we need comprehensive PFAS restrictions in the UK,” added Kirton.

Confirming that chemical alternatives are available in the bakery and snacks packaging sector, Napierska said countries where regulations have been put in place – such as Denmark – have effectively incentivized companies to avoid using PFAS compounds in paper-based food packaging.

“However, it’s not easy to name the alternatives as the information from manufacturers is often confidential,” Napierska said.

The companies add chemicals to create special products, so they don’t tell downstream users which chemicals they use. Instead, they often label their products as ‘PFAS-free’.

“It is not easy to find out which alternatives are used by packaging manufacturers,” said Geueke.

However, manufacturers, legislators and consumers can find more information on PFAS on ChemSec’s website or in a recently published database on PFAS alternatives.

Europe’s regulatory landscape

“Continuing to use PFAS can leave organizations vulnerable to evolving regulations and restrictions, reputational risks, trade restrictions and limited opportunities for product circulatory,” said Kirton.

All food packaging and other food-contact articles in Europe are regulated under the Framework Regulation EC 1935/2004. Specific regulations exist for certain types of food-contact materials, notably the Plastic Regulation 10/2011.

“In addition to many retailers, investors and consumers are calling for PFAS-free packaging, and governments are also making PFAS-free products a legal requirement, too,” said Kirton.

More countries are committing to action on PFAS, including the European Union (EU) and some nations are also introducing their domestic legislation. In 2020, Denmark banned using PFAS in paper-based food packaging.

The UK’s Health and Safety Executive published a PFAS Risk Management Options Analysis (RMOA), which makes recommendations for managing PFAS and has been accepted in principle by the UK Government. These recommendations include further examination of PFAS in food packaging. Given the increasing levels of PFAS in the environment and evidence of harm, legislation will be needed to address this issue.

“Inconsistencies in the current Food Contact Materials (FCMs) Regulation – mainly gaps – exist and compromise its aims of ensuring chemical safety and functioning of the internal market,” claimed Napierska.

“The EU rules on chemicals in food contact materials chemicals are less protective than other EU chemical regulations.”

Zero Waste Europe published a policy briefing in 2023 detailing its assessment of the EU’s regulatory landscape for food packaging.

“What has changed since then is there will be a wide ban at the EU level on the intentional use of PFAS in all kinds of food packaging through the Packaging and Packaging Waste regulation,” she added.

The regulation is expected to be adopted by the end of 2024, meaning such a ban will be enforced from mid-2026.