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PFAS in Food Contact Materials

Disclaimer: This document provides guidance and is not a legally binding interpretation and shall therefore not be relied upon as legal advice.

What are PFAS substances?

PFAS stands for poly- and perfluoroalkyl substances. This is a large family of chemical substances which comprises more than 6,000 substances. PFAS have very useful chemical and physical properties, such as resistance to fire, and repellency to dirt and water. For this reason, PFAS are used in all kinds of consumer products.

PFAS are controversial because they are hazardous for human health and the environment.

Due to new scientific insights certain chemicals belonging to the PFAS family are included in the REACH candidate list for authorisation as a SVHC. Some PFAS are included in the REACH Annex XVII restriction list under entry 68.

PFAS in Food Contact Materials (FCMs)

PFAS can be used in carton and paper FCMs, for example, cardboard pizza boxes or cardboard containers for popcorn or French fries. The reason for PFAS use in paper and board FCMs are its grease repellant properties.

There is no European harmonised legislation for food contact materials made from paper and board.
Denmark is in this moment of time the only country in the EU which has banned all PFAS in food packaging.

The Netherlands will ban the use of four PFAS substances in all food contact materials as of July 1st, 2022, however “paper and board” is considered as the only potential FCM which might contain the four banned PFAS substances.  

According to the recent published amendments in the Dutch Packaging and Utensils Regulation (Warenwetregeling verpakkingen en gebruiksartikelen) the following four PFAS substances may not be used in the manufacturing of food contact materials and may not be present in FCMs as a contamination. 

The ban of these four PFAS in the updated Dutch WVG was subject of a consultation with Dutch stakeholders. The outcome of this consultation was that there is no need to arrange a transitional period. 

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