PFAS Contamination in Food from Food Packaging Materials

PFAS chemicals and contamination

There has been much coverage and discussion about per- and polyfluorinated alkyl substances (PFAS) contamination in water sources, soil and sediment. Lately, the conversation and dialogue has focused on the contamination of food due to PFAS in food packaging. PFAS chemicals in food packaging can migrate into food, especially when food containers, packaging, and wrappers that contain PFAS are exposed to fatty, salty, or acidic foods.

Also referred to as “forever chemicals,” the PFAS class of man-made chemicals contains over 9,000 known compounds. These compounds are resistant to biodegradation and do not easily break down in the environment. As a result, PFAS chemicals have been shown to bioaccumulate, or build up, in humans and wildlife with exposure. Although the US Food and Drug Administration (FDA) has provided guidance regarding authorized uses of PFAS in food contact applications, the presence of these forever chemicals in food packaging is particularly concerning, as small amounts of PFAS in the body can lead to serious health problems. Specific PFAS chemicals have been linked to a myriad of health issues, such as cancer, suppressed immune function, and reproductive toxicity, including birth defects and infertility, developmental toxicity, and preeclampsia in pregnant women.

Authorized uses of PFAS in food contact materials

Four general categories for the application of PFAS in food contact materials have been authorized by the FDA:

  • Coatings for non-stick cookware;
  • Resin-based components used in food processing equipment, including gaskets and O-rings;
  • Processing aids for manufacturing other food contact polymers, and
  • Paper and paperboard food packaging to prevent the seeping of grease through packaging.

For food contact substances to be granted authorization by the FDA for market entry, upon review of the data provided, the FDA must find that under the intended conditions of use, there is a reasonable certainty of no harm. It is important to note that food contact authorizations can be rescinded by the FDA when warranted. Several factors influence the ability of PFAS chemicals to migrate into food and contaminate food products, including the molecular structure of the substance, the manufacturing process for the product, and its intended use.

To better understand the potential sources of contamination of food from paper and paperboard food packaging containing PFAS chemicals, it is helpful to first have general knowledge of how PFAS are applied to paper packaging materials, as outlined by the FDA. The grease-proofing agent is created by attaching PFAS molecules as smaller “sidechains” to other non-PFAS polymerized molecules. The grease-proofing agent is then applied to applied to paper and paperboard packaging at lower temperatures. The lower temperatures used in the application process do not allow for the removal of residual, smaller PFAS molecules. These smaller, residual PFAS molecules have the potential to migrate into and contaminate food products. Therefore, under certain conditions, the smaller PFAS “sidechain” can detach from the polymerized molecule, migrating into and contaminating food.

Voluntary phase-out of certain PFAS-containing food contact materials

3 manufacturers of food contact substances containing a particular short-chain per- and poly-fluoroalkyl substances (PFAS), 6:2 fluorotelomer alcohol (6:2 FTOH), agreed to participate in an FDA-led voluntary phase-out of these compounds in 2021. The food contact substance 6:2 FTOH has a history of use as a grease-proofing agent in some paper and paperboard food packaging. The 3-year voluntary phase-out of sales of these compounds in the US marketplace began in 2021. It is understood that, after the 3-year phase-out period comes to an end, it may take up to 18 additional months to exhaust the stock of products containing 6:2 FTOH currently on the market.

Originally, 4 companies were granted authorization for the use of these short-chain grease-proofing agents by the FDA, as a result of the standard Food Contact Notification (FCN) process. While 3 companies have agreed to participate in the voluntary phase-out, in 2019, the fourth manufacturer voluntarily stopped sales of food contact substances containing 6:2 FTOH, later reporting this decision to the Agency. At the time the FCNs for short-chain PFAS became effective, data demonstrated they were a safe alternative to long-chain PFAS. In the time that has passed since the original authorization was granted, the Agency has carried out post-market scientific reviews. Data that the FDA reviewed as part of this process showed reports of biopersistence of 6:2 FTOH in rodent studies. This data pointed to the conclusion the chemical may also potentially persist in humans after consuming food which has been exposed to the compound. Although further studies are needed in order to better understand the risk 6:2 FTOH presents to human health, the phased removal of these materials from the market limits the potential for supply chain disruption while addressing the potential public health risk.

The regulation of PFAS in food packaging and food contact materials

To evaluate whether PFAS levels pose a potential human health concern, the FDA conducts safety assessments when detectable levels of PFAS are found in foods. The Agency considers several factors, including:

  • Whether an action level of tolerance has been established;
  • How much of a specific food is typically consumed;
  • The level of contamination detected, and
  • The toxicity of the contaminant.

The FDA has cited various resources for toxicological reference values (TRVs) for PFAS, and has recently started using the finalized minimal risk levels (MRLs) in the May 2021 Toxicological Profile for Perfluoroalkyls from the Toxic Substances and Disease Registry, as well as a new EPA reference dose, also finalized in 2021.

Action to regulate acceptable limits of PFAS in food contact and food packaging materials is also being pursued at the state level. In October of 2021, California Assembly Bill (AB) 1200 effectively banned all plant fiber-based food packaging containing intentionally added PFASs. Furthermore, plant fiber-based food packaging with PFAS present at levels exceeding 100 parts per million total fluorine have been banned. Although the legislation does not take effect until January 1, 2023, the precedent that has been set by the state of California with this new law has led to speculation that further legislation and regulation of PFAS in food packaging, including trace limit levels, will soon follow.

Measuring PFAS in food and food packaging with FDA analytical methodology

The FDA has been refining an analytical method using liquid chromatography-tandem mass spectrometry (LC-MS-MS) for the testing of food matrices for the presence of 16 PFAS analytes since 2012. Over time, the methods have been expanded, validated, and further optimized for processed food matrices. The Agency plans to publish further revisions to the methodology in spring or summer 2022. These revisions will allow for the detection of 4 additional PFAS compounds, extending the method from 16 to 20 types of PFAS. These new compounds will include PFUda, PFDoA, PFTrDA, and PFTeDA.

Impact’s highly knowledgeable scientists have the experience and expertise to apply the FDA PFAS testing methodology to a variety of samples, including food and food packaging materials. With deep experience in analytical method development and validation, Impact can revalidate the existing FDA method for paper and paperboard food packaging material.

PFAS contamination testing is critical to preventing PFAS exposure

PFAS compounds serve a variety of purposes, and often used for their oil, grease, and water repellent properties. PFAS are also a key component of fluoropolymers, which are central to the manufacturing of non-stick cookware. PFAS are found in a wide range of food contact materials, including microwave popcorn bags, grease-proof containers, fast food wrappers, and pizza boxes. With many potential sources of exposure and contamination, implementing a robust PFAS testing strategy with a validated analytical method is key to identifying and preventing PFAS contamination. Moreover, with state-led legislation on the horizon, food packaging manufacturers looking to stay ahead of upcoming policies and legislation will need the support of a consultative, proven PFAS testing lab to ensure food contact and packaging materials comply with regulations. Impact’s highly skilled teams of consultative scientists provide industry-leading analytical solutions, including LC-MS/MS PFAS testing per FDA analytical methods validated for several food matrices. Join the leading organizations that trust Impact to deliver results that meet or exceed current regulatory limits.

Impact has the capacity and ability to analyze a diverse range of sample matrices, from consumer products, tissues, biosolids, emulsions and fluoropolymer dispersions, to food, feed, and agricultural products. Given our flexibility, capacity, and highly sensitive PFAS testing methodology, Impact is a recognized leader in comprehensive PFAS testing solutions. If you are ready to start the conversation about partnering with Impact to implement a PFAS testing program or to discuss PFAS contamination testing, talk to a scientist today.