The Food Packaging Forum (FPF) has responded to the European Chemicals Agency’s (ECHA) call for evidence on substances in packaging and packaging waste with a comprehensive data package designed to support evidence-based decision making to protect public health and the environment.
The call for evidence is part of ECHA’s implementation of the EU’s Packaging and Packaging Waste Regulation (FPF reported). FPF provided ECHA with an overview of the scientific evidence for chemicals present in single-use food packaging in the EU/EEA with curated data from the Database on Migrating and Extractable Food Contact Chemicals (FCCmigex).
To make the shared data as applicable as possible, the FCCmigex was filtered to entries where the chemical had been detected in a food contact article at least five times (to ensure the finding is robust) and at least one of those times was a single use material that had been purchased from within the EU/EEA. Only about half of the FCCmigex database entries currently contain country of origin, yet even with this limitation, FPF was able to share information on 458 chemicals.
The following is a brief overview of the written comment. The entire FCCmigex is available to explore on FPF’s publicly accessible dashboard. The call for evidence period ended on October 28, 2025.
Evidence highlights
FCCmigex
Drawing on 1,498 references, FCCmigex documents at least 5,005 food contact chemicals detected in migration and extraction experiments worldwide, with over 1,000 identified in European food contact articles.
ECHA provided a list of 200 chemicals, of which FPF was able to share evidence that 12 had been robustly detected in single-use food packaging on the European market, two of which are known to be hazardous.
In a follow-up step, FPF provided evidence for another 446 chemicals present in European single-use food packaging, 145 of which (33%) are known to be hazardous.
Industry interviews
FPF also shared published findings from Packaging Technology & Research LLC interviews with 80 packaging experts, which indicated that six of ECHA’s 200 chemicals are likely present in food contact uses (4 hazardous) and identified an additional 635 likely present chemicals (440 hazardous). While the interview outreach targeted US experts, it is reasonable to expect overlap with the EU/EEA.
Uses and drivers of substitution
To support prioritization, FPF linked chemicals to functional uses where possible via PlastChem (FPF reported), Plastic Health Map (FPF reported), and FPF’s FCChumon database (FPF reported). The comments also flagged substances with harmonized hazard data using the Food Contact Chemicals Priority List (FCCprio, FPF reported).
Why it matters
In the comment, FPF explains that food packaging is “a direct and preventable exposure source of the European population to hazardous chemicals,” pointing to emerging research linking exposures to long-term health effects, including breast cancer (FPF reported also here) and metabolism/endocrine disruption (FPF reported).
ECHA’s own work has shown that benefits from restricting selected phthalates exceeded business costs by more than tenfold (FPF reported), suggesting that restrictions on hazardous packaging chemicals could deliver substantial net societal gains.
Looking ahead, ECHA is now set to use this collected information to prepare a study for the European Commission to identify chemicals of concern in packaging and related components. It should assess the impact of these chemicals on packaging safety, reuse, and recycling with an expected submission by September 2026.
Based on ECHA’s findings, the European Commission will evaluate potential follow-up measures, which may include restrictions on certain substances used in packaging materials if they pose risks to human health or the environment. Any such restrictions will be implemented through the existing REACH restriction process.
Reference
Food Packaging Forum (October 2025). “Data submission to the call for evidence for substances in packaging and packaging waste.”
