On August 24, 2026, the Food Packaging Forum (FPF) submitted comments to the European Chemicals Agency (ECHA) in response to an invitation for feedback on ECHA’s draft list of substances of concern (SoCs) in packaging. Preparation of the list is part of work supporting implementation of the EU’s Packaging and Packaging Waste Regulation (PPWR) (FPF reported), which requires the European Commission, with support from ECHA, to prepare a report on the presence of SoCs in packaging and packaging components.
ECHA developed the draft list from a previous call for evidence (FPF reported). The screening process started with approximately 6,000 substances reported to be present in packaging and packaging waste. Following validation of packaging uses and assessment against set criteria, around 700 substances were identified as SoCs. They were primarily identified based on their status as substances of very high concern (SVHCs) under existing EU regulation, their harmonized classification for selected chronic health effects, or their classification as persistent organic pollutants (POPs).
ECHA notes that identification of a substance as SoC within the study does not automatically trigger regulatory obligations or restrictions. However, the findings are expected to inform future discussions on the management of SoCs in packaging, including potential follow-up measures and considerations related to packaging recyclability requirements.
In its letter, FPF welcomed ECHA’s effort in developing the draft list and noted that it represents an important step toward addressing known hazardous chemicals being used in packaging. At the same time, FPF highlighted opportunities to further strengthen the approach used to identify SoCs.
Scope of the substances of concern definition
FPF specifically pointed to the scope of the criteria used to identify SoCs. While acknowledging the value of relying on established European regulatory classifications, FPF noted that these criteria do not capture all known hazardous chemicals for which scientific evidence exists. FPF commented that additional hazard information from other jurisdictions and scientific sources could help support a more comprehensive identification of SoCs in packaging.
FPF compared ECHA’s draft SoCs list with data from its publicly available FCCprio List, a hazard-based prioritization of food contact chemicals. FPF submitted information on 458 chemicals in response to the call for information on SoCs. Of these chemicals, 147 are identified as hazardous by at least one regulatory source included in the FCCprio List, while 42 of those hazardous chemicals are not currently captured in the current ECHA draft SoCs list.
Recyclability considerations
FPF also commented on the inclusion of substances identified as potentially hampering recycling, requesting additional clarification regarding how conclusions from supporting Joint Research Centre (JRC) work were translated into the draft list and how future methodological updates could be incorporated to ensure the list reflects the latest scientific evidence.
Future maintenance of the list
Finally, FPF commented on the necessary long-term maintenance of the list. It noted that hazard classifications under REACH, CLP, and related regulatory systems continue to evolve as new information becomes available. Consequently, FPF emphasized the importance of treating the SoCs list as a living document that can be updated over time to incorporate new scientific, regulatory, and technical information as it becomes available.
Reference
Food Packaging Forum (August 24, 2026). “Feedback on the Draft PPWR Substances of Concern List.” (pdf)
