Why PFAS Were in Your Food Container
PFAS-treated paper and paperboard food packaging—designed to resist grease and moisture from hot foods—has been a pervasive source of PFAS exposure for decades. Fast food wrappers, pizza boxes, microwave popcorn bags, and take-out containers were routinely treated with fluorotelomer-based coatings that prevent oil and water from penetrating the paper. When heated, these coatings migrate PFAS into food at measurable concentrations. FDA analyses of FDA-approved food contact articles found PFAS migration from treated packaging into fatty foods at concentrations of 20–500 ng/kg—contributing meaningfully to dietary PFAS intake, particularly for frequent fast food consumers.
FDA Phase-Out and Industry Commitments
FDA reached a voluntary phase-out agreement with food packaging manufacturers in 2020, under which the three largest suppliers of PFAS-based food contact materials (Inhance Technologies, Archroma, and AGC Chemicals) committed to stop manufacturing and selling these substances for food contact use by January 2024. This followed FDA’s 2019 revocation of approval for 72 PFAS substances as food additives—substances that had been used in food contact applications for decades. However, the voluntary phase-out applies only to long-chain PFAS and some short-chain variants; manufacturers transitioning to alternative short-chain PFAS may still be outside the phase-out scope.
US State Legislation: 14 States and Counting
Following California’s precedent (AB 1200, effective January 2023), 14 US states have enacted laws prohibiting PFAS in food packaging. The coalition includes Washington, Colorado, Maine, Minnesota, New York, Maryland, Connecticut, Vermont, Hawaii, Illinois, Oregon, and Rhode Island. These laws define PFAS using broad class definitions (any compound with at least one perfluorinated carbon) and prohibit both intentionally added PFAS and PFAS above trace contamination thresholds (typically 100 ppm total fluorine) in finished food packaging. Enforcement by state AGOs has targeted both domestic manufacturers and importers of non-compliant packaging from Asia.
EU Food Contact Material Restrictions
The EU’s food contact material (FCM) restrictions on PFAS—Commission Regulation (EU) 2023/2055—set specific migration limits for PFAS in food contact materials effective from 2023 with phased implementation through 2025. The regulation applies to all food contact materials (paper, board, plastic, metal) and covers 24 specific PFAS compounds plus a sum parameter for PFAS total migration. EU retailers including Lidl, Aldi, IKEA, and H&M committed to phasing out PFAS in food packaging and food service products by 2024 under the ZDHC (Zero Discharge of Hazardous Chemicals) programme, accelerating industry transition ahead of regulatory deadlines.
Alternative Technologies and Market Transition
The food packaging industry has largely transitioned to molded fiber, PLA-lined paper, silicone-based barriers, and clay-coated papers as alternatives to PFAS-treated packaging. Major QSR chains—McDonald’s, Wendy’s, Chipotle, Panera Bread—have committed to PFAS-free packaging portfolios by 2025, driving upstream supplier transitions. The transition is not frictionless: alternative barrier coatings may have different performance characteristics for high-grease, high-heat applications, and cost differentials exist. But the market is moving decisively—PFAS food packaging is rapidly becoming an unmarketable product across developed markets, regardless of regulatory timelines.
The food packaging PFAS phase-out is one of the fastest sector-level transitions in chemical regulation history—demonstrating that when regulatory signals align with retailer commitments and consumer demand, industry can move rapidly even without enforcement action.