In December 2025, Health Canada published its “Science approach document on the prioritization of chemicals in plastics” describing its process for assessing “chemicals with known or potential use in plastics in Canada to identify those that may warrant further attention based on indicators of hazard and potential for human and environmental exposure in relation to their use in plastics.” In response to the accompanying request for comments, the Food Packaging Forum (FPF) submitted feedback in February 2026. A summary of Health Canada’s science approach document and FPF’s comments is provided below.
Additional, more up-to-date data sources should be consulted
Health Canada’s initial list of 16,441 substances was curated using four datasets, including the Database of Chemicals associated with Plastic Packaging (CPPdb) developed by researchers at FPF and other partners (FPF reported), and PlastChem, which was co-developed by international scientists including researchers at FPF (FPF reported). Other data sources included chemical prioritization work by Wiesinger et al. (FPF reported) and Aurisano et al. (FPF reported).
In addition to these data sources, FPF recommended consulting the latest versions of its FCCmigex. While previous versions of FCCmigex were included in PlastChem, these resources lack the most recent updates from 2025 (FPF reported). Additionally, data from FCChumon, a systematic evidence map of human exposure to food contact chemicals, including those from plastics, would add to the completeness of the chemicals list . Both resources could also provide valuable information about the use of plastics chemicals in Canada.
Clearer screening methodology required
Once a candidate list was developed, Health Canada performed a series of screening steps to identify relevant chemicals for prioritization. Chemicals known not to be used in Canadian products were omitted, as well as substances not currently listed on Canada’s Domestic Substances List (DSL). A hazard screening approach was applied to the remaining chemicals for potential human health and ecological impacts. Those chemicals found to have impacts moved onto exposure screenings, including a primary screening for chemicals used in high volumes globally, a secondary screening for human and environmental health exposures based on the release of chemicals from plastic, and a tertiary screening looking at potential exposure based on the function of a chemical in the plastic and the polymer matrix it is made up of.
In assessing these screening steps, FPF found that the methodology was unclear and difficult to reproduce, and that many potentially relevant chemicals were omitted at each step. For the hazard screening, “177 of the chemicals excluded by the Canadian prioritization results (“did not meet the hazard screening criteria”) appear to be hazardous based on the FCCprio List.” For the primary and secondary exposure screening, 383 chemicals known to be used in food contact plastics based on FCCdb were omitted and 332 chemicals known to migrate or be extractable from plastics according to FCCmigex were excluded. At the tertiary exposure screening step, FPF recommended more comprehensive screening criterion and using FCCmigex as an additional data source of chemicals known to migrate from plastic into food or food simulants.
Limitations of “classical” chemical risk assessment must be addressed
In its comments, FPF highlighted the current limitations of chemical risk assessments, which require extensive time and resources without addressing all plastic chemicals that may be relevant for human exposure. Plastics can contain thousands of non-intentionally added substances (NIAS), to which humans are exposed. However, “current tools do not allow for adequate risk characterization, harm mitigation, or adaptation (FPF reported).” As a result, FPF encouraged the Government of Canada to conduct parallel work to overcome the limitations of current chemical risk assessments, which do not address mixture toxicity, NIAS, or oligomers and the complexity of polymers.
Transparency and guidance in plastic manufacturing needed
FPF recommended transparency requirements for chemicals used to manufacture plastics, as well as the presence of chemicals in finished plastics products. It also proposed “simplifying authorized chemical lists for plastics manufacture by reducing the number of substances permitted for the same functional purpose (e.g., antioxidants).” Finally, FPF suggested capacity-building among enforcement bodies, regulators, and policymakers “to improve understanding of plastics-related chemical issues.”
References
Government of Canada (December 2025). “Science approach document on the prioritization of chemicals in plastics.”
Food Packaging Forum (February 4, 2026). “Comments on the approach and results of investigations for 6,604 substances specified on the Domestic Substances List, Canada Gazette, Part I, December 6, 2025.” (pdf)
