Environmental groups have strengthened calls for thorough regulatory review of per- and polyfluoroalkyl substances (PFASs) in food contact materials (FCMs) after discovering that the US FDA cleared several PFASs for plastic food packaging manufacture in the past decade.

The NGOs’ findings – reached through a Freedom of Information Act (Foia) request – follow the detection of PFAS contamination in fluorinated polyethylene containers, which prompted EPA and FDA investigations and the latter’s warning against unauthorised fluorination. 

In a 12 August blog, the Environmental Defense Fund (EDF) and Green Science Policy Institute (GSPI) detailed their discovery of seven food contact substance notifications (FCNs), granted between 2002 and 2016, for four PFAS processing aids for plastic packaging such as bottles and wraps. Permitted at concentrations up to 2000 parts per million (ppm), the compounds "reportedly improve polymer extrusion, reduce build-up on the injection mould and improve surface roughness, among other technical effects", the organisations said.

"While FDA has been focused on PFAS contamination from the environment and its use in paper packaging, it has been allowing PFAS-laden plastic to also contaminate the food supply without considering the cumulative effect of their dietary exposure on people’s health," they said.

EDF, GSPI and other non-profits petitioned the agency in June to ban new PFASs and revisit already permitted ones by factoring in accumulating impacts from the chemical class. 

The American Chemistry Council (ACC) said "the EDF blog relies on the misleading assumption that the mere presence of any per- and polyfluoroalkyl substance represents a health risk; however, nowhere in the text is evidence of this presented". 

Different PFASs possess "unique properties and uses, as well as environmental and health profiles", the trade association told Chemical Watch. "It is neither scientifically accurate, nor appropriate, to group them all together."

Foia results
Tom Neltner, the EDF’s chemicals policy director, said he filed the Foia request for the FCNs after packaging makers disclosed during an early 2020 workshop that they utilised PFASs to create plastic. 

The blog authors noted that in one case, the documents showed exposure from the compounds’ migration into food could be above some PFASs’ safe drinking water threshold.

"The FDA was allowing food to be contaminated at significant levels even though the agency was simultaneously realising there were problems," Mr Neltner said. "We were dismayed, but given the agency’s track record with FCNs, not particularly surprised." 

The non-profits added that the agency overlooked PFAS exposure from plastics that help store, process and transport food ingredients. And the agency failed to adhere to its regulation requiring class-based evaluation of substances with comparable toxicological outcomes, they said. 

Plastic processing aids and fluorinated polyethylene are the "latest additions to a growing list of sources of ‘forever chemicals’ in the diet", the NGOs said. The agency should assess all these compounds’ total impact across their entire range of applications, they said.

PFAS pollution is widespread, the organisations said, and "overall exposure adds up quickly" due to bioaccumulation, which increases possible hazardousness. 

‘Rigorous safety assessment’
The FDA told Chemical Watch the agency "conducts a rigorous scientific safety assessment of information submitted" before permitting any food contact substance.

The agency examines "the nature of the packaging components, the potential cumulative exposure to the food contact substance into the food and beverages (from all food contact substances that the FDA has reviewed) and safe levels of exposure", it said.

The "safety assumptions embedded in our exposure assessments mean that the actual dietary exposure from the approved food contact use is well below our cumulative dietary exposure estimate," the agency said. "Where new information raises safety questions, the FDA may revoke authorisations if the agency is no longer able to conclude that there is a reasonable certainty of no harm from the authorised use."

3M, which initiated four of the FCNs under its name or that of subsidiary Dyneon, told Chemical Watch "certain fluoropolymers used as components in polymer processing additives (PPAs) are critical to the efficient production of lightweight and high-quality flexible plastic packaging". According to 3M, their great molecular weight and low mobility decrease environmental and health concerns.

The FDA’s authorisations demonstrate its "determinations that those chemicals are safe for their intended uses, and as indirect food contact substances, should be available for use in flexible plastic food packaging", the corporation said.

The other FCN submitters, Daikin and Arkema, did not immediately respond to requests for comment

Mars, Incorporated has today announced it will incorporate recycled polypropylene plastic into the primary packaging for some of its popular pet food brands. For Mars, this marks an important step in its efforts to reduce virgin plastics use across its packaging portfolio, to do its part to build a circular economy where no packaging becomes waste.

Through its partnership with global packaging supplier Huhtamaki and petrochemical leader SABIC, Mars will use recycled plastic which has been manufactured using an advanced recycling process for its pet food packs. Thanks to this process, the packs will not feel or be different from those made with traditional virgin plastic but will have the added benefits that they include recycled material coming from previously used plastic products.

The recycling approach used by SABIC to make its certified circular polypropylene is one of the only solutions currently available that is able to take mixed, used plastic that is otherwise hard to recycle via traditional recycling routes, and to transform them back into plastic suitable for new food-grade recycled packaging. Mars is piloting this in Europe in 2020 and will increase volumes used into 2021, with ambitions to expand the use of recycled content to other brands.

Barry Parkin, Chief Procurement and Sustainability Officer at Mars, Incorporated, said: “Plastic packaging littering our land and oceans is not acceptable, and at Mars, we’re committed to helping address this problem. To do this, we need to reduce packaging we don’t need, redesign the remaining packaging to become circular and invest to close the loop to help scale up recycling systems.

“Through our partnership with Huhtamaki and SABIC, we will test-and-learn, progressively scale up recycled plastic content in our packs, and ultimately help drive circular packaging systems.”

The recycled material is certified under the ISCC PLUS (Institute of Sustainability & Carbon Certification) scheme that uses a “mass balance” approach. This widely recognized international sustainability certification scheme verifies the quality and authenticity of the recycled material along the supply chain from feedstock to final product.

The partnership comes as part of Mars’ Sustainable Packaging Plan and ambitions to use 100% reusable, recyclable or compostable packaging by 2025. Using advanced recycling technology will be an instrumental part to achieving use of 30% recycled plastics and to reduce virgin plastic use by 25%.

Charles Héaulmé, President and CEO of Huhtamaki, said: “We are fully committed to playing our part in building a circular economy across the value chain and partnering with others to do so. Our strategic partnership with Mars and SABIC is a great example of how collaboration can result in breakthroughs that deliver significant progress in our journey to designing 100% of our products to be recyclable, compostable or reusable by 2030. This new flexible packaging structure with recycled food-grade plastic is an important milestone on our journey towards achieving more than 80% of raw materials we use to be either renewable or recycled.”

Mark Vester, Global Circular Economy Leader at SABIC, said: “We are proud to show how this collaboration with Mars and Huhtamaki reflects our trust and willingness for innovation and a shared constructive and pioneering spirit. At SABIC we are committed to developing new solutions to meet our customers’ demands for increasingly sustainable solutions. SABIC’s certified circular products from our TRUCIRCLE™ portfolio offer a carbon footprint reduction of 2kgs of CO2 for every kilogram of polymer produced diverted from incineration. Only through partnerships such as this can we prove the commercial viability and sustainability contribution of advanced recycling processes to help confront the challenges our society is facing today.”

This work is part of Mars’ mission and responsibility to help create a healthy planet on which all people can thrive – a belief that’s at the heart of the Mars’ $1 billion Sustainable in a Generation Plan.