Recently, there have been increasing concerns regarding PFAS in the food packaging materials. PFAS is a group of man-made chemicals and is restricted in many countries.
PFAS (Per- and Polyfluoroalkyl Substances) are fluorinated organic chemicals containing at least one fully fluorinated carbon atom (i.e. at least one aliphatic -CF2- or -CF3- element). PFAS includes PFOA (Perfluorooctanoic Acid), PFOS (Perfluorooctane Sulfonate) and many other chemicals.
PFAS can impart oil, water, stain, and soil repellency, chemical and temperature resistance, friction reduction, and surfactant properties to products and have been widely used in the past.
PFAS has been found in food packaging materials (paper and paperboard for food packaging), consumer products including stain- and water-resistant fabrics and carpeting leather and apparel, non-stick cookware (e.g. Teflon), polishes, waxes, paints, cleaning products, and fire-fighting foams.
Certain PFAS, e.g. PFOA and PFOS have been found very persistent in the human body, and can lead to adverse health outcomes. Animal studies indicate PFOA and PFOS can cause reproductive and developmental, liver and kidney, and immunological effects. Both chemicals have caused tumours.
PFAS have been restricted in many major countries and regions, for example:
| Country /Region | Regulation | Products Scope | Restricted PFAS and Limits | Applicable Date |
| China | Ministry of Ecology and Environment Notice No. 10 of 2019 | Substances, products | (1) PFOS and its salts: shall not be used;(2) PFOSF: shall not be used. | 26 March 2019 |
| EU | POPs Regulation (Regulation (EU) 2019/1021) | Substances, mixtures, articles |
(1) PFOA and its salts ≤ 0.025 mg/kg (25 ppb); (2) PFOA-related compounds ≤ 1 mg/kg (1000 ppb) (sum) |
4 July 2020 |
| EU | REACH SVHC | Substances, mixtures, articles |
(1) Pentacosafluorotridecanoic acid: ≤ 0.1%; (2) Tricosafluorododecanoic acid: ≤ 0.1%; (3) Henicosafluoroundecanoic acid: ≤ 0.1%; (4) Heptacosafluorotetradecanoic acid: ≤ 0.1%; (5) APFO: ≤ 0.1%; (6) PFOA: ≤ 0.1%; (7) PFNA and its sodium and ammonium salts: ≤ 0.1%; (8) PFDA and its sodium and ammonium salts: ≤ 0.1%; (9) PFHxS and its salts: ≤ 0.1%; (10) PFBS and its salts: ≤ 0.1%; (11) 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propionic acid, its salts and its acyl halides: ≤ 0.1% |
Various, have applied |
| Denmark | Executive Order No. 681 of 2020 | Food contact materials made of paper and board | PFAS: shall not be used. | 1 July 2020 |
| Canada | SOR/2012-285 and Amendment SOR/2016-252 | Substances, products |
(1) PFOS and its salts, its related substances: shall not be contained; (2) PFOA and its salts: shall not be contained; (3) C7-C8 PFAS: shall not be contained; (4) C9-C21 PFCAs and their salts: shall not be contained; (5) C8-C20 PFAS: shall not be contained. |
1 January 2017 |
| US Maine | 06-096 C.M.R. ch. 890 | Certain children’s products | PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant. | 28 July 2020 |
| US Washington | HB2658 | Food packaging | PFAS: not intentionally added. | 1 January 2022 |
| Washington CHCC (173-334 WAC) | Certain children products |
(1) PFOA and related substances: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant; (2) PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant. |
21 August 2011 | |
| US Vermont | Vermont CHCC (18 V.S.A. chapter 38A) | Certain children products |
(1) PFOA: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant; (2) PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant. |
10 June 2014 |
| US Oregon | Oregon HPCCCH(OAR-333-016) | Certain children products | PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant. | 1 January 2016 |
| US New York | New York Environmental Conservation Law, Section 37 Title IX | Certain children products |
(1) PFOA and related substances: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant; (2) PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant. |
1 March 2020 |
| S.8817 and A.4739-C | Food packaging comprised of paper, paperboard, or other materials originally derived from plant fibers. | PFAS: not intentionally added. | 31 December 2022 | |
| US Rhode | S.218 | Food packaging | PFAS: not intentionally added | 1 January 2020 |
| US Massachusetts | S.1315 (SD 678) | Food packaging | PFAS: not intentionally added | 1 January 2020 |
| US California | Proposition 65 | All products |
(1) PFOA: not pose a significant risk; (2) PFOS: not pose a significant risk |
10 November 2017 |
| US California, San Francisco | San Francisco Ordinance No. 201-18 | Food service ware | PFAS: not intentionally added | 1 January 2020 |
Following restrictions on PFAS have been also proposed in major countries and regions, for example:
| Country /Region | Regulation | Products | Proposed Restricted PFAS and Limits |
| EU | REACH Annex XVII | Substances, mixtures, articles | (1) C9-C14 PFCAs and their salts: < 0.025 mg/kg (25 ppb);(2) C9-C14 PFCA-related substances: ≤ 0.026 mg/kg (260 ppb) (sum) |
| US | Toxic in Packaging Model Legislation | Package or packaging components | PFSA not detachable. |