Last week, we spent two days at a Chemical Watch food packaging conference with manufacturers and suppliers trying to better understand the process for bringing innovative products to market. They learned what the Food and Drug Administration (FDA) and other countries will demand and what challenges they need to anticipate. While regulatory aspects are complicated, the attendees often talked about the difficulties of navigating requirements from companies and reacting to consumer expectations about packaging chemicals.
These concerns were timely. On March 9, the Food Safety Alliance for Packaging (FSAP), a part of the Institute of Packaging Professionals, released “Food Packaging Product Stewardship Considerations,” a set of best practices. This marks the first public recognition by a sector of the packaging industry of the expectations and demands from food manufacturers, retailers, and consumers.
Key Considerations
The guidelines were developed by a working group of food company packaging experts. The goal was to provide a roadmap for packaging suppliers and producers on both quality issues and opportunities to minimize or eliminate chemicals of concern in food packaging. A key objective was to harmonize the many different lists individual companies may have. Compliance with applicable regulations is a given.
Substances that must not be used:
- Heavy metals – cadmium, chromium VI, lead, mercury – in any packaging component including inks, pigments and colorants;
- Perfluoro and polyfluoro-compounds with 8 or more carbons to grease-proof coated paper and paperboard; and
- Polystyrene for oven or microwave applications.
Substances that should not be used where suitable alternatives exist include:
- Ortho-phthalates in any packaging component;
- Bisphenol A-based materials in can coatings and plastic resins;
- Styrene in excess of 400 ppm (parts per million) in polystyrene resin for film or rigid structures;
- Toluene in printing ink formulations; and
- Wooden pallets treated with bromo- or chloro-phenol chemicals as wood preservatives.
The following substances were among those whose use should be minimized:
- Perfluoro and polyfluoro compounds shorter than 8 carbons to grease-proof coated paper and paperboard;
- Natural rubber latex unless applied only to sealing areas that avoid food contact;
- Antimony from antimony-based catalysts in PET resin in excess of 300 ppm; and
- Printing solvents with a maximum residual in cured ink in excess of 20 mg/m2 of surface area and 7 mg/m2 of total combined ketones and acetones.
In California, chemicals on the Proposition 65 list should not be used at levels where presence of the chemical must be communicated. In Europe, Substances of Very High Concern identified by the European Chemicals Agency (ECHA) should not be used in any packaging component.
Recycled Materials
The document also calls for use of recycled materials based on conditions of use. For instance, post-consumer recycled plastic should be used when a favorable opinion from FDA has been given for the specific process utilized. Recycled paper, solid board, and corrugated board should be used based on an evaluation of supplier-provided testing results using the Recycling Paper Technical protocol. Recycled solid board should not exceed a target average level of 600 ppm of mineral oil hydrocarbons in unprinted material.
Conclusion
EDF encourages all companies in the food supply chain—from packaging component producers to retailers—to use Food Packaging Product Stewardship Considerations to strengthen their stewardship efforts, increase transparency and better integrate legal requirements, food safety, product quality, environmental protection, and consumer interest.
Tom Neltner, J.D., is Chemicals Policy Director and Maricel Maffini, Ph.D., Consultant
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