Members of the Food Packaging Forum (FPF) submitted feedback highlighting aspects of food packaging and chemical safety for Environment and Climate Change Canada (ECCC) to consider during development of a pollution prevention (P2) planning notice for primary food plastic packaging. Specifically, ECCC is considering “targets for reduction, reuse, redesign, and recycled content” (FPF reported).
As FPF’s expertise is mainly on chemicals in food packaging, we focused our remarks on this aspect, with additional comments on how the concerns about chemical migration extend to reuse and creating standards for compostable materials. A shortened version of the comment follows.
Chemicals of concern
We strongly urge the ECCC to consider in its pollution prevention plan the issue of chemical migration, and to develop its plans with this matter in mind, to avoid any unintended adverse impacts on human health.
The presence of hazardous chemicals in plastics should be prevented from the design stage to avoid harm to humans and the environment through the entire plastic life cycle. Importantly, hazardous chemicals used in the manufacture of all types of food packaging (and other materials) will be perpetuated in the reuse and recycling of products (FPF reported). As such, the presence of hazardous chemicals in food packaging (plastics as well as their alternatives) is a threat to human health and the environment, and a barrier to enabling the circular economy. Hazardous chemicals in food packaging will hinder the successful implementation of Canada’s plastic targets if not sufficiently addressed.
Supporting safe reuse
We urge the ECCC to take care when supporting plastic as a reusable material. Instead we would encourage adopting reuse and refill programs based on inert materials.
Scientists from Health Canada are already investigating the relationship between chemicals used in food contact and obesity (Heindel, et al. 2023; Health Canada). While we are not aware of estimates of the economic impacts to Canada, in the US phthalates (often used in plastics) are estimated to cost $39.9–47.1 billion in lost economic productivity per year (FPF reported). Also, the annual disease burden and associated economic costs of exposure to long-chain PFAS in the US are estimated to be at least $5.52 billion and up to $62.6 billion (FPF reported). Restricting the use of problematic chemicals and chemical groups in plastic packaging or certain reuse or recycling scenarios could therefore be both a significant benefit to public health and the resulting economic costs across the production, use, and waste stages of the value chain.
For the selection of plastic alternatives, we recommend the use of the Understanding Packaging (UP) Scorecard (FPF reported). The UP Scorecard is a free, web-based tool to assess human and environmental health impacts of foodware and food packaging products. It compares the products across six metrics: plastic pollution, chemicals of concern, climate, water use, sustainable sourcing, and recoverability. The tool offers companies a first-ever, free, and comprehensive resource for making more sustainable and lower risk for chemical migration packaging decisions.
Compostable materials
ECCC aims to “set minimum standards for products to be labelled compostable.” It is essential that such a minimum standard includes a specific time frame of biodegradation, standardized methods to demonstrate safety, and standardized methods to assess the complete degradation into CO2, water, inorganic compounds, and biomass.
Compostable packaging is by definition designed to enter the organic waste stream and become part of the open environment. Industrial composting typically has a turnover rate of 4-12 weeks but the complete degradation of compostables can take longer (e.g. ECCC 2013), any minimum standard for compostability needs to be aligned with locally established commercial practice. ECCC should additionally include a clear statement that compostable packaging needs to be free of hazardous chemicals. Special focus should be given to chemicals that are persistent, such as PFAS.
Packaging manufacturers should therefore be required to provide information on the safety and complete decomposition (i.e., complete mineralization) under realistic industrial composting conditions (e.g., certain temperature, humidity, soil pH, presence of relevant microorganisms, and other essential parameters) before the product is placed on the market. ECCC may also consider requiring labels that instruct users on the correct way to dispose of specific packaging items, as well as warnings for consumers that being compostable does not mean it will disappear if disposed of in the environment.
References
Parkinson, L., et al. (August 30, 2023). “FPF comment on ECCC development of a pollution prevention (P2) planning notice for primary food plastic packaging.” Environment and Climate Change Canada. (pdf).
Heindel, J., et al. (2023). “Obesogens and Obesity: State-of-the-Science and Future Directions Summary from a Healthy Environment and Endocrine Disruptors Strategies Workshop.” The American Journal of Clinical Nutrition. DOI: 10.1016/j.ajcnut.2023.05.024
Health Canada (2022). “Health Canada: Compilation of research abstracts 2020-2021.”
