Packaging, especially single-use plastic, has been in the news a lot lately. Images of a straw in a turtle’s nose. Stalled community recycling programs following China’s decision to severely limit what waste materials they’ll accept. Hundreds of companies committing to change their plastic packaging practices. And let’s not forget about chemicals associated with packaging. In our previous blog, we noted that tight virgin-material standards can prevent problematic contamination in post-consumer recycled materials. We also shared a list of ten toxic chemicals and chemical classes including PFAS, phthalates, and perchlorate that can migrate into food from food packaging and food handling equipment.
If you’re a food manufacturer or a grocer and packaging hasn’t been getting much attention at your company, now might be a good time to refocus. If your company is among the many that have signed on to the Ellen MacArthur global commitment to tackle plastic waste and pollution and you haven’t yet addressed the chemicals found in your packaging, the time to act is definitely now. EDF has identified five key steps to consider for achieving better food packaging:
- Set new packaging specifications for suppliers: You can begin tackling problematic chemicals by simply setting new specifications for your suppliers about the packaging chemistry that you will and will not allow. New supplier expectations can be incorporated into existing packaging or product specifications. A good place to start is by calling for the exclusion of EDF’s previously referenced list and explicitly asking suppliers to confirm that these chemicals have not been intentionally added to packaging. Should you want to go further, consider incorporating the Food Packaging Product Stewardship Considerations, developed through the Food Safety Alliance for Packaging, a technical committee of the Institute of Packaging Professionals. Final packaging may seem the obvious starting point, but intermediate packaging used throughout food processing and handling can pose substantial issues as well. For example, flexible intermediate bulk containers, or “super sacks,” used to transport grains and other dry ingredients in food processing facilities may be laden with the problematic anti-static agent perchlorate, a neurotoxin of special risk to pregnant women, infants, and young children. We maintain that super sacks are an important route for perchlorate to migrate into food. We encourage companies to create a safer food policy – a company’s written commitment to customers and suppliers to drive safer food to the market. A safer food policy is also a good vehicle for articulating packaging improvement goals. You can see EDF’s model safer food policy here.
- Verify compliance: Once you have your packaging specifications in place, verifying compliance is the next step. One mechanism for doing so is CONEG certificates. In 1989, the Council of Northeast Governors (CONEG) developed model legislation now known as The Model Toxics in Packaging Legislation banning the intentional use of lead, cadmium, hexavalent chromium, and mercury in packaging and its components, including inks, coatings, closures and labels and limiting total residual contamination from these heavy metals. Nineteen states have adopted this model; it is also the basis of the European Union’s Packaging and Packaging Waste Directive (94/62/EC). Under the CONEG system, buyers verify compliance through certificates that packaging suppliers must provide. States verify compliance by asking buyers to provide the certificates upon request. You can tap into this existing system by adapting the CONEG certificates to include information about the presence of other priority chemicals, such as the EDF list recommended above. Click here to see examples of a CONEG certificate modified to address these additional packaging chemicals. Sample testing is also helpful in verifying compliance. Testing food and packaging for the presence of the chemicals of concern you have identified can be a useful way to spot check the veracity of information you’ve received via modified CONEG certificates. We’ll explore testing options in detail in a future post.
- Track progress: Tracking progress helps you determine if the actions you’re taking are working as intended. Reporting on progress also reinforces with your suppliers – and your customers, if reporting is public – that packaging chemistry is a priority issue for your business.
- Collaborate: Many of the toxic chemicals we identified, such as PFAS and phthalates, are in widespread use. This challenge can also be an opportunity for precompetitive collaboration, to identify and scale the use of safer alternatives. Joining forces with initiatives such as the Food Safety Alliance for Packaging mentioned earlier may be a good way to engage. Within your own supply chain, increasing dialogue and the flow of information among converters, material suppliers, and designers will help too.
- Develop a pilot: Pilots can help you learn which strategies for supplier engagement, data collection, and tracking progress work and can be replicated once you’re ready to scale. Starting small can be especially helpful for grocers or large food manufacturers with deep product portfolios. Your pilot could focus on one or two product categories, such as dairy, where the science indicates target chemicals are most expected. Or your pilot could focus on a category like baby food, where toxic chemicals have been found and the exposure could be more damaging because of consumer age. Or your pilot could target food packaging used at the carry-out counter in your stores. Click here for sample ideas for pilots.
Though it can seem daunting at first, meaningful action to remove toxic chemicals in packaging is achievable by taking steps like these. Soon you, too, can be on your way to enhancing the quality of your products, improving the recyclability of post-consumer materials, and protecting public health.
By: Boma Brown-West and Michelle Mauthe Harvey
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