Scientists at the Food Packaging Forum (FPF) submitted comments on the European Food Safety Authority’s (EFSA) draft scientific opinion on the re-assessment of the risks to public health related to the presence of styrene in plastic materials and articles intended to come into contact with food. The public consultation on this draft opinion closed on January 28, 2025.
Insufficient scope
The scientific opinion falls short of expectations in two key areas. Firstly, we argue that evaluating the risks of styrene itself is insufficient to determine the safety of food contact materials (FCMs) made with styrene. Scientific studies have demonstrated that at least 94 chemicals migrate from polystyrene (PS), including styrene monomers, oligomers, non-intentionally added substances (NIAS), and other plastic-related compounds. These data are summarized in the database on migrating and extractable food contact chemicals (FCCmigex). Notably, styrene is not only used and present in PS and has been detected in other FCMs such as paper and board, polypropylene (PP), and recycled polyethylene terephthalate (PET; FPF reported).
To comprehensively assess health risks, it is necessary to evaluate the combined toxicity of all migrating substances from these materials, considering both genotoxic and non-genotoxic effects. However, EFSA’s draft opinion only assesses toxicity based on the genotoxic potential of styrene after oral exposure. This narrow approach is questionable, for instance in light of EFSA’s 2023 decision to significantly reduce the tolerable daily intake (TDI) of bisphenol A (BPA) due to immune system effects rather than genotoxicity (FPF reported). We argue that EFSA should similarly consider broader toxicological mechanisms in the assessment of styrene-related health risks, particularly given that styrene is suspected to be toxic for reproduction and its pending assessment for endocrine disruption.
Transparency and bias
Furthermore, we express concerns about EFSA’s reliance on industry-funded studies, including unpublished research. The lack of transparency in such studies raises concerns about potential biases in regulatory decision-making.
Given these reasons, we conclude that EFSA’s draft opinion does not provide sufficient evidence to determine that styrene can be safely used in FCMs at the proposed level.
References
European Food Safety Authority (December 12, 2024) “Draft scientific opinion on the re-assessment of the risks to public health related to the presence of Styrene in plastic materials and articles intended to come into contact with food.”
Food Packaging Forum (January 28, 2025) “Comment on PC-1239.”
