The 10th annual Food Packaging Forum (FPF) workshop “Taking stock of the past decade: What has changed and what’s to come?” took place in Zurich, Switzerland on October 6, 2022. Over 150 participants joined in-person and online. This article summarizes the presentations and panel discussions given during the morning of the workshop around the theme of scientific and regulatory progress in the last ten years. Recordings of the presentations by individual speakers are available online. There is an additional article focusing on the afternoon sessions sharing examples of sustainable programs from the real world and what the future may bring.
The workshop began with a presentation by Martin Scheringer, president of the board of the FPF, who summarized the impacts of the FPF during the last ten years and especially highlighted the databases on food contact chemicals and their multiple applications.
The first panel of the workshop focused on discussing key scientific advancements in the field over the last decade. Pete Myers, founder of Environmental Health Sciences and adjunct professor at Carnegie Mellon University; Ana Soto, professor of immunology, Tufts University; and Julien Boucher, founder and director of Environmental Action, began the discussion sharing their thoughts of the last ten years.
Soto and Myers focused on the growing evidence of the effects of endocrine disrupting chemicals and how, despite this increasing knowledge base, action has been slow. Soto shared her recollection of the 1991 Wingspread conference where she and other participants created the term “endocrine disruptor.” She states that at that time experimental evidence was already sufficient to know many chemicals had hormonal effects. Some of those predictions have since become true: for example, increasing experimental evidence supporting concerns around mixture toxicity and fluorinated compounds such as PFAS.
Boucher focused on the application of this growing evidence: “we are trying to aggregate all this important information developed through the science and put it in an actionable framework.” He says that food packaging safety and the concerns Soto and Myers raise have gotten to a strategic level in companies. “Ten years ago when we were doing life cycle assessment [LCA]… we were assessing packagings, but at the end of the day packaging was not representing a lot of the impact in an LCA… it was not so important. And then around 2015-16 came the plastic crisis… and that was one of the advancements in our field was bringing plastic pollution back into LCA” (FPF reported).
But what are the biggest challenges to integrating these concerns into analysis and regulation? Boucher explained that “we know enough” there is ever more data about the effects of plastics and other forms of packaging on our health but “the next one [challenge] is bringing… the fascinating and also worrying science of toxicity and ecotoxicity into the LCA type of decision-making.” Soto takes another step back, instead of considering the effects of small technological changes, she argues that “we are bound to an old paradigm… we have to start from the beginning and say– what is packaging doing? What is the minimal problem packaging is addressing and start rethinking it.” Meanwhile, Myers looks to the future, “when a fetus gets exposed [to EDCs] in the womb… the signals can transmitted faithfully across the generations… There is no regulatory agency that has begun to work on this.”
Following the panel were several talks reviewing what global regulatory authorities have been up to – what has improved and what’s currently in the works.
Pelle Moos, senior policy adviser at BEUC – The European Consumer Organization, reviewed the last decade of FCM regulations in the EU. Ten years ago DG SANCO (now DG SANTE) released a roadmap for materials regulation in the EU titled “Materials on the market are not safe.” In 2016 the European Parliament took up the issue due to concerns that the lack of uniform EU measures was detrimental to public health (FPF reported, also here) and in 2017 the Joint Research Consortium concluded that food contact material (FCM) rules in Europe were a regulatory patchwork (FPF reported). The big change was the announcement of the European Green Deal and within it the Farm to Fork strategy outlining legal reform across the entire European food system in order to improve food safety and public health (FPF reported).
Following the new strategy, the European Commission (EC) will revise the EU FCM legislation to not only improve safety and health but support the use of innovative and sustainable materials and contribute to food waste reduction (FPF reported). The day before the workshop the EC opened a public consultation survey for consumers and food contact material stakeholders (FPF reported). According to Moos, surveys show European consumers are concerned about the chemicals they are exposed to. BEUC is launching another survey on public perceptions, the findings will be released in February 2023.
Member of European Parliament Christel Schaldemose joined the workshop remotely to share her thoughts on the revision of the EU FCM regulation, “what is interesting is the fact that both industry and consumer side are asking for this revision.” She has three main goals for the revision: (i) establishing the precautionary principle for FCMs, (ii) no data – no market, “if you [companies] don’t come up with your data you should not go on the market with your product”, and (iii) creating a unified market standard for all companies. Schaldemose adds that enforcement is also crucial but tricky in the EU. In her opinion, Europe is too slow, “we have the knowledge, we know that it is unsafe… and [some] things contain dangerous chemicals.” It is also about “creating a fair-level playing field,” so companies that are ahead of the curve do not get unfairly disadvantaged.
The EC may not publish the new FCM regulation proposal until summer 2023, which would push adoption into the next political cycle. Parliament would like to speed that up but Schaldemose states, “honestly, I’m not sure that we will be able to deliver on the speed, however most important of course is that we deliver on the content.”
Lisette van Vliet of Breast Cancer Prevention Partners, a US civil society organization, shared her thoughts on chemical regulation in the US. The US Food and Drug Administration (FDA) has been coming under increasing pressure from congress and the public as stories of shortcomings within the food safety branch of the agency continue to come to light (FPF reported, also here). The US Congress has developed proposals for restructuring the FDA, reforming the generally recognized as safe (GRAS) rule, and has requested a report from General Accounting Office which should be published in the near future (FPF reported, also here). In the meantime, individual states have stepped in. PFAS in food packaging is regulated for nearly a quarter of the US population thanks to state-level regulation (FPF reported, also here). Other state level legislation in California, Maine, and elsewhere regulates use of single-use plastics, phthalates, recycled content, and recycling and composting systems for packaging (FPF reported, also here). Van Vliet believes the increasing media coverage of issues around chemical exposure is helping raise consumer awareness.
Jorge Emmanuel, adjunct professor at Silliman University in the Philippines, opened his talk with the impossibility of the task he was given- reviewing food packaging regulation over the last ten years “in Asia” within 15 minutes. He asked the audience, “do you know how big Asia is?” Instead of trying to sum up the regulatory actions of all 45+ countries stretching from the middle of the Pacific to the Middle East, Emmanuel focused on the countries with the greatest populations. He gave a whirlwind tour of the regulatory changes in China, India, Indonesia, Japan, Thailand, and his home of the Philippines (FPF reported, also here and here). In all of them the last decade has seen the nations move from few to no standards for food packaging to ever greater regulation and, importantly, enforcement.
For example, a survey by the Food Standards and Safety Association of India (FSSAI) in 2016-17 found that 100% of food packaging tested failed to meet standards set in 2006. In response, the FSSAI established chemical migration limits, and clearer definitions along with labeling, traceability, and documentation requirements that it has continued to update (FPF reported).
Emmanuel also discussed two broader issues across Asian nations: the ubiquity of melamine in consumer dishware and the sachet economy. He urged workshop attendees and regulatory authorities in the region to “think of the exposure” and the “exposure to mixtures” that takes place when so many different consumer products contain chemicals known to cause harm. In the Philippines there are 1.3 million neighborhood stores which “once had an active reuse system.” However, “multinationals completely destroyed a sustainable practice” and the now ubiquitous sachets have “caused lots of problems.” 164 million sachets are sold every day in the Philippines alone.
The final panel of the morning session built off the specific concerns brought up in the regional policy reviews and began to discuss what is necessary to move forward. Specifically, “what haven’t we managed?”
Independent consultant Maricel Maffini’s main concern was that there is “no systematic program to look back at safety determinations made years ago.” There are some chemicals on the market in the US and Europe that were approved 50 years ago, before we understood the long-term exposure. The US Congress specifically stated in 1958 that the cumulative effects of chemicals in the diet should be assessed but the FDA never has (FPF reported).
Xenia Trier, associate professor of environmental analytical chemistry at the University of Copenhagen, said we need to prevent harm to people and the planet by avoiding known hazardous chemicals, but also complete chemical classes even if single chemicals have not been assessed completely. “Delaying action will lead to spreading of harm… we have to go towards preventing harm.” Studies show that preventive action, i.e., the precautionary principle, is justified in the vast majority of cases – more than 95%, Trier claims. “Our regulations are based on risk assessment, but if we cannot foresee future uses we cannot do risk assessment. So the one way to avoid it is to avoid putting harmful chemicals in there.”
Valentin Fournel, director of eco-conception CITEO, is concerned about getting everyone at the table. He gave an example of his work in France concerning mineral oils in packaging. At the time, no one was sure where the mineral oil was coming from. By getting packaging manufacturers, recyclers, and ink producers all together they were able to find where the mineral oils came from and jointly develop a way to lower the level in packaging. All the ink companies collectively changed their ink production to lower the amount of mineral oil. And now, several years after adjusting to the lower levels, regulations are going further to ban mineral oils (FPF reported).
All three panel members continued to discuss the difficulties of regulating, studying, or recycling increasingly complex materials. Replacing hazardous chemicals may lead to higher chemical/material complexity or lower performance. Trier and Fournel proposed to accept reduced performance (e.g., by shortening the shelf-life of cans from ten to two years), if this can increase chemical safety.
References
Martin Scheringer (October 6, 2022). “10 Years of FPF: Highlights and Impacts.” YouTube
Pelle Moos (October 6, 2022). “FCMs in Europe: What has changed during the last 10 years?” YouTube
Christel Schaldemoose (October 6, 2022). “FCM regulation in Europe: Update from the European Parliament.” YouTube
Lisette van Vliet (October 6, 2022). “FCMs in the US: What has changed during the last 10 years?” YouTube
Jorge A. Emmanuel (October 6, 2022). “FCMs in Asia: What has changed in the last 10 years?” YouTube
FPF (October 6, 2022). “2022 Workshop: Taking stock of the past decade: What has changed and what’s to come?”
