FDA’s Voluntary and Regulatory PFAS Phaseouts
The U.S. Food and Drug Administration has taken a phased approach to removing PFAS from food contact materials. Following scientific reviews linking food packaging PFAS to human exposure, FDA worked with manufacturers to voluntarily discontinue three categories of PFAS-based grease-proofing agents for paper and paperboard food packaging in 2016, 2020, and 2024.
The 2024 phaseout covered the remaining authorized PFAS uses in food contact materials, marking a significant milestone in eliminating this exposure route. However, the FDA’s voluntary approach has been criticized for allowing slow transitions and failing to address PFAS in other food-related materials such as food processing equipment coatings and non-stick cookware.
State-Level Food Packaging PFAS Bans
Numerous states have enacted outright bans on PFAS in food packaging, often moving faster than federal action. California, Washington, Vermont, Connecticut, Minnesota, and Maine are among the states that have prohibited intentionally added PFAS in food packaging, with effective dates ranging from 2023 to 2025.
Fast food packaging — including grease-resistant burger wrappers, pizza boxes, and microwave popcorn bags — has historically been a major source of PFAS exposure. The state bans have driven major fast food chains to transition to PFAS-free packaging alternatives, effectively creating national changes through state regulation.
Enforcement and Compliance Verification
Enforcement of food packaging PFAS bans presents challenges because fluorine-containing compounds used as PFAS alternatives — sometimes called ‘fluorine-free’ coatings — may degrade to form PFAS. Testing methodologies including total organic fluorine measurement are being used to verify compliance and identify non-conforming products.
International trade considerations complicate enforcement when food products packaged overseas enter domestic markets. Customs and state agriculture departments are developing testing protocols to screen imported packaged foods for PFAS-containing packaging.