The Food Packaging Forum (FPF) submitted comments to the U.S. Environmental Protection Agency’s (EPA) public consultation on the draft Sixth Contaminant Candidate List (CCL 6). The list covers contaminants that are currently not subject to any national primary drinking water regulations but are “are known or anticipated to occur in public water systems and may require regulation under the Safe Drinking Water Act (SDWA) in the future.” The consultation closed on Jun 5, 2026.
While the draft CCL 6 includes 75 chemicals and four chemicals group, FPF’s comments focused on the group “microplastics” for which the draft states that “there are currently data gaps that require further research before the Agency can fully understand the health risks associated with microplastics in drinking water.”
In its comments, FPF
- supports EPA’s proposal to include microplastics in CCL6 and argues that actions to reduce exposure should not be delayed but begin now
- emphasized that emerging evidence links exposure to micro- and nanoplastics to adverse human health outcomes. While further research is essential to close existing knowledge gaps, FPF explained that the available evidence supports consideration of the precautionary principle, which holds that a lack of scientific certainty should not delay action to prevent potential harm to human health. The fact that humans consume tap water known to contain microplastics on a daily basis, resulting in continuous and widespread exposure, further supports the application of the precautionary principle.
- stressed that nanoplastics should be considered alongside microplastics, particularly since smaller particles may pose greater risks because they can more readily cross biological barriers.
- emphasized that plastic particles are introduced into drinking and tap water via many sources and recommended reducing plastic production to comprehensively address exposure to micro- and nanoplastic via drinking water and other sources. FPF further highlighted that a robust global plastics treaty could become a powerful tool to address plastic-related health and environmental impacts. Importantly, this would require countries to align and agree on limits to plastic production.
- drew the EPA’s attention to food packaging and other food contact articles (g., food packaging and processing equipment) as well as FPF’s FCMiNo database, which demonstrates the release of micro- and nanoplastics under normal and intended use conditions (FPF reported). Highlighting that this exposure is avoidable, FPF recommended determining the migration propensity of micro- and nanoplastics before market placement of food contact articles.
Reference
Food Packaging Forum (May 28, 2026). “Comments on draft CCL6, docket number EPA-HQ-OW-2022-0946.” (pdf)
