Per- and polyfluoroalkyl substances (PFAS) refer to an expansive array of chemicals that have been used in industrial applications since the 1940s. There are thousands of different types of PFAS, estimated to include as many as 10,000 chemical compounds, which are utilized for countless applications. PFAS are oil, water, and friction resistant and can withstand significant variations in temperature. PFAS are used in textiles, paper, cookware, fire suppression foams, and packaging. They are used widely in industries such as aerospace, microchip manufacturing, automotive, construction, aviation, and food packaging, among many others.
Given their uniquely valuable properties and range of uses, PFAS were initially hailed as wonder compounds. In 1967, FDA approved the first PFAS for use in food packaging. In the decades that followed, PFAS were used in the packaging of countless thousands of products. Currently, FDA’s Inventory of Food Contact Substances Listed in 21 CFR includes more than 30 PFAS. Such a listing means the agency has deemed the PFAS safe for their intended use and allows them to be legally marketed as food contact substances.
The Problems with PFAS
Once heralded, PFAS have turned out to be decidedly more problematic than previously imagined. They are long-lasting, environmentally destructive, and potentially toxic. PFAS take an extraordinarily long time to break down. Decades of widespread use have led to dangerous environmental accumulation. These “forever chemicals” can now be reliably detected in the oceans, drinking water, soil, plants, other animals, food, and even our own blood. Numerous studies indicate a causal link between human and animal health problems and environmental exposure to PFAS.
PFAS are subject to significant backlash, and food companies may soon face a litany of risks by continuing to use PFAS in their packaging.
In recent years, there has been a significant push by consumers, scientists, environmental advocacy groups, and many companies seeking to end the use of PFAS, especially in food packaging. Numerous food companies—including household names like Chipotle, McDonald’s, Panera, Taco Bell, Whole Foods, and Wendy’s—have pledged to stop using food packaging manufactured with PFAS. Additionally, Connecticut, Maine, Minnesota, New York, Vermont, and Washington have enacted laws banning the use of PFAS in food packaging.
The federal government has also been getting in on the act. In 2016, FDA banned manufacturers from using long-chain PFAS in food packaging. These are even longer lasting than the comparable “short-chain” PFAS. However, after the discovery that at least one short-chain PFAS continued to linger in the body after consumption of a food contaminated with the compound, FDA and manufacturers partnered in announcing that they would phase out use of the compound as a food container coating.
On October 18, 2021, EPA Administrator Michael S. Regan announced a strategic roadmap aimed at significantly reducing the use of the chemicals, including a comprehensive strategy to address the problem.
According to EPA, exposure to high levels of certain PFAS has been shown to lead to adverse health outcomes; however, research is ongoing to determine how different levels of exposure to various PFAS can lead to a variety of health effects. Research is also underway to better understand the health effects associated with low levels of exposure to PFAS over long periods of time, especially in children. These are difficult questions to answer for many reasons. The sheer ubiquity of these chemicals and our continuous exposure to them makes it difficult to identify correlations. Additionally, it is exceedingly difficult to identify which problems are attributable to which of the thousands of PFAS in widespread use. Consequently, it will take time to get clear answers.
What is clear is that PFAS are subject to significant backlash, and food companies may soon face a litany of risks by continuing to use PFAS in their packaging. Among these risks are geographical sales constraints, regulatory violations, lawsuits, and product boycotts.