PFAS Restrictions in Food Contact Materials
PFAS (Per- and Polyfluoroalkyl Substances) are fluorinated organic chemicals containing at least one fully fluorinated carbon atom (i.e. at least one aliphatic -CF2- or -CF3 element). PFAS includes PFOA (Perfluorooctanoic Acid), PFOS (Perfluorooctane Sulfonate) and many other chemicals.
PFAS are often used in food contact materials, such as bakery bags and takeaway boxes, due to their grease and water-resistant properties. However, they can migrate from these materials into food or drink and pose a threat to human health.
EU and more than ten U.S. States have already imposed restrictions on PFAS in food contact materials. Following is the summary of the earlies effective date for the FCM related requirement:
Earliest Effective
Date (Year) |
Region |
| Restriction Rules |
| 2019 |
EU POPs |
| 2020 |
EU POPs, California/San Francisco |
| 2021 |
U.S. Toxics in Packaging Clearinghouse Model Legislation(TPCH) |
| 2022 |
California/Santa Rosa, Maine, New York |
| 2023 |
EU REACH Annex XVII, California, Connecticut, Maine, Vermont, Washington |
| 2024 |
California, Colorado, Hawaii, Maryland, Minnesota, Rhode Island |
| 2030 |
Maine |
| Reporting Rules |
| 2011 |
Washington (Chemicals of High Concern to Children) |
| 2014 |
Vermont (Chemicals of High Concern to Children) |
| 2018 |
Oregon (High Priority Chemicals of Concern for Children's Health) |
| 2020 |
Maine (Priority Chemicals) |
| 2023 |
Maine |
In EU and UK-NI, REACH Annex XVII Entry 68 will come into force in 2023, it is restricting the use of C9-C14 PFCAs and related substances.
In 2023, 5 states in US are enforcing the restriction of the PFAS usage. Out of the 5 states’ requirement, California AB 1200 is of most concern. Per AB 1200, less than 100 ppm of total organic fluorine is allowed. Also, if there are chemicals (including PFAS) in the designated list, manufacturer should post the information in the internet website (in 2023) and on product label (in 2024).
In 2023, reporting of intentionally added PFAS to Maine authority is requested.
More and more regions are imposing the PFAS restriction, with expertise from Intertek, manufacturer can cope with the PFAS challenge effectively.
About Intertek
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