On September 26, 2023, an international team of over 20 scientists, led by Food Packaging Forum (FPF) director Jane Muncke shared a to work toward a world where food contact materials are free from hazardous and untested chemicals. Published in the peer-reviewed journal Environment International, the collaborative effort from scientists of FPF, its Scientific Advisory Board, and other academics propose a new conceptual approach to move beyond current risk assessment procedures for food contact materials. At present, assessments focus on one chemical at a time, particularly cancer-causing chemicals that are genotoxic (i.e. damage DNA). In the future, the authors envision assessing the whole cocktail of chemicals that migrate from finished food contact articles (FCAs) and testing their effects with respect to multiple growing health concerns including cardiovascular disease and metabolic disorders.

The authors highlight that current safety evaluations focus primarily on the substances used in the manufacturing of food contact articles, overlooking compounds that emerge during production. As a result, many chemicals in food packaging and cookware remain untested, especially the interactions with non-intentionally added substances (NIAS), despite the fact that these chemicals are relevant for human exposure.

To address these gaps, Muncke et al. suggest (1) testing the whole cocktail of chemicals that migrate from the final food contact article, including (unknown) NIAS, and (2) broadening toxicological evaluations to cover a variety of non-communicable diseases, beyond just genotoxic effects.

Six Clusters of Disease framework

The researchers developed the six clusters of disease (SCOD) concept, highlighting prevalent and increasingly concerning non-communicable diseases (NCDs) linked to chemical exposures: cancers, cardiovascular diseases, as well as reproductive, brain-related, immunological, and metabolic disorders. For instance, widely used food contact chemicals (FCCs) like PFAS, bisphenol A, and phthalates have ties to conditions like kidney cancer, infertility, and ADHD, respectively (FPF reported, also here and here).

For some of these associations, mechanistic evidence exists that helps to understand the modes of action – how these chemicals exert their toxic effects. Mechanistic data are generated for example by in vitro experiments (e.g., with cell cultures) or in silico (i.e., computational) predictions, such as cell-based assays or quantitative structure-activity relationship (QSAR) models, respectively. This mechanistic evidence provides opportunities to use in-silico and in-vitro assays to better map toxicity profiles of individual chemicals in finished FCAs, before they are placed on the market, as well as mixtures, extracts and migrates from food contact materials and articles. The SCOD provides organizing principles for such an approach, namely what types of assays shall be selected for comprehensive testing strategies.

While governments including the US, EU, Canada, and China have risk assessment requirements, typically only intentionally used substances undergo evaluations.

The vision

The scientists’ vision is based on the idea that in-depth chemical testing can curb non-communicable diseases. The paper proposes a novel approach for testing FCCs that
  1. Covers individual FCCs as well as real-life mixtures, migrating (or extractable) from finished food contact articles, including all known and unknown NIAS,
  2. Assesses the health impacts of FCCs and real-life mixtures with respect to the most prevalent non-communicable diseases in the human population as laid out in the SCOD, and
  3. Evaluates effects that are upstream from the disease, relying on mechanistic information and high-throughput in-vitro screening approaches (wherever possible) to predict health effects induced by FCCs and migrates, building on Adverse Outcome Pathways and Key Characteristics of Toxicants (FPF reported) concepts.

This approach supports initiatives like the EU’s Chemicals Strategy for Sustainability, the EU Farm to Fork Strategy, and the European Parliament’s report on FCMs, which emphasize the need for improving food contact material safety (FPF reported). It also resonates with ongoing efforts in the United States, where the Food and Drug Administration is strengthening post-market review of food contact substances (FPF reported).

According to the authors, this vision offers guidance for the further development of FCM safety assessment. With the goal to enhance public health protections globally and emphasizing the universal urgency for improved safety of food packaging and other FCMs.  


Muncke, J. et al. (2023) “.” Environment International. DOI:

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Scientific Advisory Board. Food Packaging Forum