On June 20, 2024, the Food Packaging Forum (FPF) submitted comments to the US Food and Drug Administration on a proposed rule amending the Food Additives Regulations to remove authorization of fluorinated polyethylene. The Food Additives Petition was filed by a coalition of civil society organizations and independent scientists on April 26, 2024, including the Environmental Defense Fund, Breast Cancer Prevention Partners, Center for Food Safety, and the Environmental Working Group.
The following is a shortened version of FPF’s comment. The original version is one of 13 published comments, available under docket FDA-2024-F-1912, and containing further links to supporting scientific studies.
Direct fluorination of plastics involves exposing polyethylene to fluorine gas, modifying the plastic’s surface and properties. However, for nearly two decades, it has been known that perfluoroalkyl carboxylic acids (PFCAs) are generated in this process if oxygen is present. PFCAs have been shown to migrate from fluorinated plastic containers into food, directly exposing humans to PFCAs when consuming food packaged this way (FPF reported). PFCAs and other per- and polyfluoroalkyl substances (PFAS) are hazardous to human health even at low concentrations. Many PFAS found in food packaging have not been tested for toxicity, making it impossible to confirm their safe use (FPF reported). Notably, all PFAS are persistent, raising significant environmental and human health concerns (FPP reported).
PFAS have been widely used in paper and board food packaging, with recent regulatory actions leading to or aiming at their phase-out in the US and in European countries (FPF reported here and here). However, the use of fluorinated polyethylene in food contact materials remains an ongoing source of exposure to hazardous PFAS. Therefore, scientific evidence supports this petition to remove the authorization of fluorinated polyethylene to reduce human exposure to PFCAs and protect public health.
Track other opportunities to contribute to regulations on food contact chemicals and materials on FPF’s consultations page.
References
Food Packaging Forum (June 20, 2024). “Comment on Food Additive Petition FDA-2024-F-191.” US Food and Drug Administration.” (pdf)
