On March 30, 2021, the journal PLOS Biology published an article authored by Jane Muncke from the Food Packaging Forum (FPF) that critically reviews the migration of toxic chemicals from plastic food packaging, comments on the current approach to plastic packaging toxicity testing, and suggests three key aspects for improvement.

In her essay, Muncke argues that one widely overlooked issue of plastic packaging is the transfer of potentially harmful chemicals from packaging to food. Some migrating chemicals such as bisphenol A (BPA; CAS 80-05-7) are known to be hazardous to humans, however, for many other substances, including non-intentionally added substances (NIAS), toxicity data are missing. Since migrating hazardous chemicals from plastics have been associated with chronic health effects, these known and avoidable exposure routes of hazardous chemicals should be eliminated.

However, the article argues that “[..] the current approach to understanding and improving the chemical safety of plastics food packaging [is flawed and] needs to be revised.” Muncke identifies three key aspects that need to be considered: (1) expanding the scope of toxicity testing beyond genotoxicity, (2) addressing non-monotonic dose responses in chemical risk assessment, and (3) finding practical solutions to assessing and managing mixture toxicity, i.e. identifying the hazard properties of all chemicals migrating simultaneously from plastics.

One such practical solution could be the introduction of a mixture assessment factor (MAF) for known migrating substances (FPF reported). Another concept known as “key characteristics,” originally applied to determine whether a substance is potentially carcinogenic through in vitro bioassays, has also now been developed for other groups of toxicants such as endocrine-disrupting chemicals (FPF reported). Wider application of the concept could lead “to a more complete hazard characterization of chemicals migrating from plastic food packaging.” Muncke concludes: “The plastic pollution problem requires systemic thinking that shies away from quick fixes addressing only one symptom of the larger problem. Instead, robust innovations will be built on a thorough, holistic understanding of the plastics problem that must be developed by integrating all available knowledge—including hazardous chemicals—across plastic’s entire life cycle.”

The European Commission (EC) will carry out a full impact assessment for their revised food contact material (FCM) Regulation 1935/2004, and a legislative proposal is expected to be finalized in the fourth quarter of 2022 (FPF reported).

In November 2020, FPF published a publicly available food contact chemicals database (FCCdb) on intentionally added food contact chemicals (FCCs) that are globally potentially used in the manufacture of FCMs and food contact articles (FPF reported). Instructions on how to use and retrieve information from the database are available on our resources page. For more information regarding mixture toxicity and non-monotonic dose-response, Muncke discusses both concepts in the second episode of the “Unwrapping Food Packaging” video blog.


Jane Muncke (March 30, 2021).Tackling the toxics in plastics packaging.” PLOS Biology