Grease-resistant and water-repellent coatings applied to paper and fiber-based food packaging have long been a significant pathway for human PFAS exposure. The chemicals migrate from the packaging into food, particularly hot, fatty, or acidic items that come into prolonged contact with treated surfaces. As awareness of this exposure pathway has grown—and as analytical detection methods have improved—regulators on multiple continents have moved to eliminate PFAS from food contact materials, creating a global supply chain transformation for the food packaging industry.
United States: FDA Action and State Laws Lead the Way
In the United States, the Food and Drug Administration (FDA) accepted voluntary industry commitments to phase out PFAS used in grease-resistant food packaging from 2020, and by 2024 the FDA had revoked the food contact notifications for long-chain PFAS compounds used in paper and paperboard coatings. However, the FDA’s authorization framework does not automatically prohibit residual use of previously cleared compounds, leaving a gap that state legislators have moved to fill.
California, New York, and Vermont have enacted laws specifically prohibiting PFAS in food packaging, with California’s law (AB 1200) requiring disclosure of intentionally added PFAS in food packaging from 2023 and prohibition of sale from 2023. New York’s ban on PFAS in food packaging took effect in 2023. Minnesota and Maryland enacted similar prohibitions in 2024. By 2025, more than 15 states had enacted some form of restriction on PFAS in food packaging—creating a de facto national standard that has accelerated reformulation by major packaging manufacturers including Graphic Packaging, WestRock, and Pactiv Evergreen.
European Union: Food Contact Materials Regulation Update
The European Union has regulated PFAS in food contact materials through its framework Regulation (EC) No 1935/2004, which requires that food contact materials must not transfer constituents into food in quantities that could endanger human health. Specific migration limits for individual PFAS have been established under Commission Regulation (EU) 2023/2006, and EFSA completed risk assessments in 2020 that established a tolerable weekly intake for the sum of four PFAS of just 4.4 nanograms per kilogram body weight per week—a level so low that it effectively rules out intentional PFAS use in food contact applications. Denmark implemented a national prohibition on PFAS in food packaging effective January 1, 2026, ahead of any harmonized EU-wide product restriction under REACH.
The School Lunch Tray Problem
One of the most politically visible PFAS food packaging issues in the United States has been the presence of PFAS in school lunch trays and cafeteria food service items. Studies by environmental groups detected significant PFAS concentrations in molded fiber trays, grease-resistant pizza boxes, and school cafeteria containers purchased under USDA National School Lunch Program contracts. Multiple states passed legislation requiring PFAS-free food service materials for public school cafeterias, and the USDA updated its procurement guidance to discourage the purchase of PFAS-containing food service items by the 2025–2026 school year.
Canada’s PFAS Food Packaging Framework
Health Canada regulates PFAS in food packaging through its Food and Drug Regulations, which establish maximum migration limits for food contact chemicals. Following the 2025 CEPA toxicity determination for non-polymeric PFAS, Health Canada is expected to update its food contact regulations to prohibit intentionally added PFAS in packaging materials—aligning with the direction set by FDA actions in the United States and EU regulatory developments. The timeline for final Canadian food contact PFAS regulations is projected to extend to 2026–2027 given the complexity of the domestic consultation process.
Connection to Water Quality
The regulation of PFAS in food packaging is directly linked to drinking water quality through two pathways. First, manufacturing facilities that produce grease-resistant paper packaging are significant point sources of PFAS discharge into wastewater, contributing to downstream water contamination. Studies of wastewater treatment plant effluents in paper-producing regions of Maine, Michigan, and the Southeast United States have detected elevated PFAS concentrations traceable to pulp and paper mills—and those discharges have contaminated municipal drinking water supplies. Second, composting facilities that process PFAS-treated paper food packaging are generating PFAS-contaminated compost that is applied to agricultural land, creating a diffuse non-point source pathway into soil and groundwater. Both pathways will require water treatment solutions as detection limits improve and regulatory scrutiny of these contamination sources intensifies.