On January 20, 2020 the Food Packaging Forum (FPF) provided written comments to the European Commission regarding its roadmap on the Circular Economy Action Plan. A public consultation on the road map was launched together with the document’s publication in December 2019 (FPF reported). In its comments, FPF highlighted the conflicting targets of reducing resource consumption by reusing and recycling materials, and the protection of human health from exposures to hazardous chemicals migrating from food packaging made from secondary raw materials. Several examples of cases where chemical safety was compromised in recycled materials are documented in the scientific literature, such as brominated flame retardants in black plastics or mineral oils in paperboard. Another issue raised in FPF’s comments is the spreading of highly persistent per- and polyfluoralkyl substances (PFAS) in the environment via biodegradable paper packaging, for example used to replace plastic take away containers. FPF recommends that the European Commission “invests appropriate funds into research and development for tools that permit ensuring chemical safety also for food contact articles that are made from recycled materials and/or intended for biodegradation, such as (high-throughput) bioassays or automated chemical screening. Importantly, issues of relevance for chemical risk assessment of food contact materials need to be taken into consideration, such as mixture toxicity and environmental persistence of chemical constituents.”


Food Packaging Forum (January 20, 2020). “European Commission public consultation on the New Circular Economy Action Plan: Comments by the Food Packaging Forum.” (pdf)