Food contact materials (FCMs) can contain hundreds of chemicals of concern. To move towards safe FCMs, free of hazardous substances, a compilation of all chemicals (of concern) used in and potentially migrating from FCMs is key. The Food Packaging Forum (FPF) has created such lists in the past, including the Food Contact Chemicals Database (FCCdb) and the Database on Migrating and Extractable Food Contact Chemicals (FCCmigex), respectively.
Now, Khairun Tumu and colleagues from Iowa State University, Ames, US, claim to have compiled a harmonized inventory on chemicals of concern in FCMs by combining the information from several publicly available Restricted Substance Lists (RSLs). Their article, published on July 29, 2025, in the International Journal of Food Science and Technology, aims to provide a practical foundation for understanding and managing chemicals of concern in food packaging, helping converters, brand owners, and decision makers to update RSLs and promote safer materials within a circular economy.
RSLs are curated inventories of chemicals that are either banned or limited in use due to their human or environmental health concerns. These lists are typically developed by regulatory agencies, industry groups, or scientific bodies to guide manufacturers, suppliers, and policymakers in managing hazardous substances.
Tumu and co-authors did not explicitly cite which lists they considered, but describe reviewing existing RSLs for (food) packaging, within which they identified 16 substance groups that they share in their publication as 16 new RSLs. These groups are organized partly by function (e.g., monomers, adhesives) and partly by chemical structure (e.g., bisphenols, per- and polyfluoroalkyl substances (PFAS)). Subsequently, they used the Toxtree software to determine the Cramer Class and Threshold of Toxicological Concern (TTC) for each of the compiled chemicals to get a rough idea of whether a substance might have a toxic effect or not. In addition, the scientists provide a short summary on selected risks, thresholds, and applications of some of the chemical groups.
The review has several critical limitations. Most notably, their applied methodology is insufficiently described, making it impossible to reproduce their work. For instance, it remains unclear which RSLs were reviewed, their version, and the date of access, and whether a systematic approach was used to select chemicals for inclusion in the newly generated lists. While Figure 1 strongly suggests that FPF’s FCCdb was a key component of the work, the database is never mentioned in the text nor cited, which is uncommon for a scientific publication. Given the overlap with FCCdb content, the authors should have acknowledged and compared their work to the FCCdb, which is more comprehensive (e.g., drawing from more sources, covering more chemicals, and providing more detailed information).
Generally, the article lacks proper citations and does not adhere to good scientific practice, with issues such as misspelled author names and missing references to regulations. Furthermore, the rationale for grouping chemicals into 16 separate RSLs, partly based on function and partly on structure, is not clearly explained. The classification of substances “with very limited… or no current application in plastic manufacturing” as NIAS is also questionable.
For a comprehensive overview on uses and hazards of food contact chemicals (FCCs), compiled and reported transparently, have a look at FPF’s resources and publications: The FCCdb compiles regulatory and industry information from 67 lists on intentionally added FCCs, identifying a total of 12,285 FCCs. It prioritizes 603 of these FCCs for further assessment and substitution due to their hazard properties (FPF reported). Based on information included in the FCCdb, 388 FCCs should be considered harmful according to the EU’s Chemicals Strategy for Sustainability (FPF reported). The list is designed for easy use by policy makers (FPF reported). Furthermore, the PlastChem database compiles over 16,000 chemicals, including non-intentionally added substances (NIAS), known to be present in plastic, including over 4,200 which are classified as chemicals of concern based on persistence, bioaccumulation, mobility, and toxicity (FPF reported).
Reference
Tumu, K. et al. (2025). “High priority chemicals of concern in industry and regulation: a compilation and analysis of publicly available restricted substance lists.” International Journal of Food Science and Technology. DOI: 10.1093/ijfood/vvaf149
