Via a public comment, the Food Packaging Forum (FPF) is encouraging the US Environmental Protection Agency (EPA) to expand the Safer Choice and Design for Environment (DfE) programs into food contact materials. FPF argues that the ubiquity of packaging as an environmental and human health issue (FPF reported also here and here), along with the known economic costs of chemical exposures of targeted food contact chemicals in the US (FPF reported also here) make food contact materials (FCMs) a prime target market for Safer Choice and DfE.
In August and September 2023, the EPA opened a public comment period for feedback concerning the potential expansion of the agency’s programs. The Safer Choice and Design for Environment (DfE) programs aim to promote the use of safer and environmentally friendly products. The Safer Choice program focuses on identifying and encouraging the use of products with safer chemical ingredients, noted in the EPA’s Safer Chemical Ingredients List (FPF reported), providing consumers and businesses with a label meant to signify product safety. The DfE program, on the other hand, works to assess and improve the environmental and human health profiles of various products, including chemicals, by collaborating with industries to reduce risks and environmental impacts. Currently, the programs focus on cleaning products with DfE additionally covering pesticides.
A shortened version of the comment follows.
The FPF’s key concern revolves around the potential migration of hazardous chemicals from FCMs. Through the combined FCCmigex and Food Contact Chemical databases, FPF has documentation for over 14,000 known food contact chemicals (FPF reported), some with known hazardous properties and linked to substantial economic costs. For example, ortho-phthalates in plastic FCMs incur annual losses of $39.9–47.1 billion, and long-chain PFAS exposure results in an annual disease burden and costs ranging from $5.52 billion to $62.6 billion.
FPF has developed or contributed to the development of two tools that could help the EPA should it decide to investigate FCMs for the Safer Choice and DfE programs, (i) Food contact chemicals of concern list, and (ii) the UP Scorecard chemicals of concern metric.
In the European Union, the Chemicals Strategy for Sustainability aims to restrict hazardous chemicals from consumer products linked to specific health outcomes (FPF reported). Specifically, chemicals that have hazard classes of concern because they are carcinogenic, mutagenic, or toxic to reproduction (CMRs), or persistent and bioaccumulative, or endocrine disrupting (EDCs) will be targeted. In 2022, FPF created a list of 388 hazardous chemicals known to be used in the manufacture of FCMs that have at least one of the hazard classes prioritized in the EU’s Chemicals Strategy (FPF reported). EPA could look into prioritizing these 388 chemicals of concern for phase-out and replacement in FCMs within the Safer Choice and DfE programs.
One tool that could support EPA in this process is the Understanding Packaging (UP) Scorecard (FPF reported). Developed collaboratively by leading food service companies, civil society organizations including FPF, and technical experts, the UP Scorecard’s chemicals of concern metric prioritizes three tiers of chemicals for stakeholders to remove from foodware and food packaging. The chemicals of concern list can serve as an actionable resource to support expansion of the Safer Choice program.
Including FCMs in the Safer Choice program is especially important in the context of achieving a truly circular economy, as hazardous chemicals that continue to be used in the manufacture of food packaging (and other materials) will be perpetuated in the reuse and recycling of these materials and products (FPF reported). Meanwhile, composted FCMs will release any present hazardous chemicals directly into the environment, which is especially concerning with the currently widespread presence of highly persistent and hazardous chemicals such as many PFAS.
In April 2022, the EPA announced Safer Choice products would be PFAS free by March 2023 (FPF reported).
Reference
Parkinson, L., et al. (September 11, 2023). “FPF comment on the expansion of the US Environmental Protection Agency Safer Choice and Design for Environment programs.” Regulations.gov.
Read more
EPA. “Safer Choice Program.”
Cailey Gleeson. (September 6, 2023). “US EPA will consider wide net in proposed Safer Choice product expansion.” Chemical Watch.
