In a peer-reviewed published on June 7, 2022, in the Journal of Hazardous Materials, researchers from the Food Packaging Forum (FPF), ETH Zürich, and the Swiss Federal Institute of Aquatic Science and Technology (Eawag), Switzerland, present an overview of chemicals intentionally used in food contact materials (FCMs) that are harmful according to the EU’s Chemicals Strategy for Sustainability ().

The researchers identified 388 food contact chemicals of concern (FCCoCs) including 352 substances that are known to be carcinogenic, mutagenic, or toxic to reproduction (CMRs), 22 endocrine-disrupting chemicals (EDCs), 32 chemicals with persistence- and bioaccumulation-related hazards, eight with persistence- and mobility-related hazards, and three with specific target organ toxicity (STOT). For 127 FCCoCs, there is empirical evidence for their presence in FCMs according to the database on migrating and extractable food contact chemicals (FCCmigex) that was published on May 19, 2022 (FPF reported). Importantly, 30 of the 127 are monomers, of which 22 have been shown to migrate into food or food simulant. This demonstrates that known harmful monomers do migrate out of food packaging under realistic use conditions, making them highly relevant for human exposure.

The authors concluded that the 388 identified FCCoCs should be prohibited for use in FCMs immediately to comply with the targets of the CSS. To arrive at safer FCMs, they consider it essential that regulatory reform moves towards generic risk assessment, allows only a defined set of safer chemicals (“positive list”), and explicitly refuses most harmful chemicals (“negative list”).

The European Union published the CSS in October 2020 to improve the protection of human health and remove the most harmful chemicals from consumer products, including from FCMs (FPF reported). The hazard properties of concern the CSS mentions include CMRs, persistent and bioaccumulative, persistent and mobile, EDCs, and chemicals with STOT. Since the CSS is fairly recent, an analysis of food contact chemicals that have CSS hazard properties had not been undertaken.

To compile the list of FCCoCs, the scientists used FPF’s Food Contact Chemicals database (FCCdb), which comprises chemicals potentially used in the manufacturing of FCMs together with their hazards (FPF reported). To this, they added information on use, production volume, evidence of migration or extraction from FCMs, and identified monomers and per- and polyfluoroalkyl substances (PFAS). The FCCoC list is ready to use by policymakers. The authors highlight that their “findings justify moving away from a risk- towards a hazard-based approach to regulation of chemicals in FCMs.”



Zimmermann, L. et al. (2022). “.” Journal of Hazardous Materials. DOI: 10.1016/j.hazmat.2022.129167

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Geueke, B. et al. (2022). “.” Critical Reviews in Food Science and Nutrition, DOI: 10.1080/10408398.2022.2067828

Groh, K. et al. (2020) “.” Environment International, DOI: 10.1016/j.envint.2020.106225

Groh, K. et al. (2020) “.” Zenodo, DOI: 10.5281/zenodo.3240108