Notpla Limited                                          PFAS0020

Written Evidence Submitted by Notpla Limited

The Case for Banning PFAS in Food Contact Packaging

Introduction

  1. Notpla appreciates the opportunity to submit evidence in connection with the Environmental Audit Committee’s inquiry into the risks from Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS).
  2. Notpla is pioneering the use of natural materials such as seaweed and plants to create sustainable packaging solutions, replacing harmful chemicals like PFAS and plastic used in packaging. Our achievements include:

○         Winner of The Earthshot Prize 2022 in the "Build a Waste-Free World" category

○         Recipient of the Tom Ford Plastic Innovation Prize 2023

○         Recognition by the Dutch government as a provider of plastic-free materials in accordance with the EU Single-Use Plastics Directive

  1. This submission presents evidence on the urgent need to ban PFAS in food contact packaging in the UK. PFAS chemicals pose significant risks to human health and the environment due to their persistence, bioaccumulation potential, and documented health impacts. Safer alternatives exist that can provide comparable performance without the associated health and environmental costs. Current UK regulatory frameworks are inadequate to address these health risks posed to citizens and a ban of PFAS in food contact packaging is urgently required.

Question 1. What benefits do PFAS provide and how widely are they used?

  1. In food packaging, PFAS is often added to prevent oil and grease from soaking through the packaging. The widespread usage extends across multiple food sectors, with takeaway food packaging, bakery products, and ready-meal containers showing the highest prevalence.
  2. A 2021 study found that PFAS chemicals are being used in disposable food packaging from popular fast-food chains, takeaway restaurants, and supermarkets across Europe, including in the UK. It found that 76% of the samples tested were intentionally treated with PFAS, and traces of PFAS were detected in all samples.
  3. The concern with PFAS was set out by the European Commission: “PFAS in food-contact materials will inevitably lead to the exposure of humans to PFAS. Due to the non-threshold nature of the PFAS hazards, exposure to PFAS from food-contact materials is an unacceptable risk for human health. PFAS should therefore be restricted in food-contact packaging.” (Para 21, PPWR).
  4. Alternatives to PFAS treatments do exist and are widely available, from natural barrier coating like Notpla seaweed based material to reusable options, all demonstrated effective oil and water repellency without the persistence and toxicity concerns of PFAS.
  5. While UK retailers have begun transitioning away from PFAS in their packaging, significant market presence of PFAS-containing packaging remains as there is no restriction placed on the materials.

Question 2. To what extent are UK health and environmental regulators equipped to detect, monitor and understand the risks posed by PFAS?

  1. A number of laboratory, such as Campden BRI and ISEGA, have developed testing methods to detect PFAS in food and drink products. While it is possible to test and monitor the amount of PFAS in an individual product, the prevalence of PFAS use in packaging application will pose challenging to have a comprehensive monitoring process.
  2. We therefore propose a ban on PFAS in food contact packaging, following the European Commission's recent adoption of similar legislation. This measure would require manufacturers to verify their products' PFAS content through external testing, a practice we at Notpla already implement through ISEGA laboratory test, which has confirmed our products contain no PFAS at a sensitivity threshold of 0.01 mg/kg (test results can be found here).

Question 4. How sophisticated is current knowledge of how and where PFAS enter the supply chain?

  1. Current understanding of PFAS entry points into UK supply chains remains inadequate, particularly regarding food packaging materials. The market shift away from plastics has led to increased adoption of alternative materials such as molded fiber, paper straws, and other coated paper products. The barrier properties necessary for food contact applications typically rely on undisclosed chemical treatments, including PFAS.
  2. The situation is further complicated by the multistep manufacturing processes typical in packaging production. Paper and board may be treated with PFAS during initial production, then converted into specific packaging forms by a different company, printed by a third entity, and filled by yet another before reaching consumers. Each transition in this fragmented supply chain creates potential information loss regarding chemical composition.
  3. This transparency gap persists largely because existing regulations do not mandate disclosure of PFAS content in packaging products. Consequently, downstream users often remain unaware of the PFAS chemicals present in materials they handle and process.
  4. We therefore advocate for mandatory disclosure requirements and standardized testing protocols to ensure comprehensive supply chain transparency regarding PFAS in food packaging materials.

Question 5. What is the current understanding of how PFAS are made and then used in terms of product ranges, and geographical and socioeconomic distribution?

  1. PFAS usage is particularly prevalent in the food service sector due to functional requirements for grease resistance in takeaway containers. A 2020 market analysis revealed significant PFAS levels in packaging from 8 of 9 major UK supermarkets tested, as well as in 100% of takeaway packaging sampled. This evidence demonstrates that PFAS use in UK food packaging is widespread across both retailers and product categories.
  2. Despite increasing awareness of PFAS-related concerns, many food service businesses remain uninformed about the chemical composition of packaging purchased from distributors, leading to unintentional continued use of these persistent chemicals.
  3. We have observed misleading marketing practices, with products labeled as containing "No intentionally added PFAS" without disclosing actual PFAS content levels. Such labeling can deceive consumers into believing products are completely PFAS-free when they may still contain these substances.

Question 8. How well equipped is the UK's research and development base to improve existing approaches to dealing with PFAS?

  1. The UK has particular strength in materials science relevant to developing PFAS alternatives for food packaging. Several universities, including Imperial College London, the University of Manchester, and the University of Sheffield, maintain active research programs in sustainable packaging materials that could provide PFAS-free alternatives. Notpla is a UK based company and has been pioneering the development of seaweed-based coating to replace PFAS and plastic lining in food packaging. It won the Earthshot Prize in 2022 and raised over £30 million to date. Puraffinity, another UK based start-up, raised £17m to scale up precision technologies which remove PFAS from water.

Question 9. Is the current regulatory regime for the use and disposal of PFAS, including UK REACH, adequate? If not, how can it be improved?

  1. The current UK regulatory framework governing PFAS in food contact materials contains significant gaps. UK REACH operates primarily on a substance-by-substance approach that is fundamentally unsuitable for addressing the thousands of different PFAS compounds in commercial use. This approach creates regulatory inefficiency and allows manufacturers to substitute restricted compounds with structurally similar alternatives that may pose comparable concerns.
  2. In the specific context of food contact materials, no limits exist for most PFAS compounds under current UK regulations. This contrasts sharply with the European Union's move toward group-based restriction through the Packaging and Packaging Waste Regulation 2025/40 (PPWR).
  3. Waste management regulations represent another area of inadequacy. Current classification systems do not designate PFAS-containing packaging as hazardous waste requiring special treatment, despite evidence that these materials can leach PFAS into the environment when disposed of in conventional landfills or composting facilities. This regulatory gap allows PFAS to continue entering the environment at end-of-life stage.
  4. Recommended improvements include:

○         Implementation of a group-based restriction approach for all PFAS in food contact materials

○         Establishment of mandatory disclosure requirements for PFAS presence in packaging materials

○         Development of appropriate classification for PFAS-containing waste streams

Question 10. Is a precautionary approach to PFAS desirable or is an approach that uses regulation to assess their benefits and risks more appropriate?

  1. A precautionary approach to PFAS in food packaging is strongly warranted based on multiple lines of evidence regarding these substances' intrinsic properties and emerging health concerns. Epidemiological studies have increasingly linked PFAS exposure to concerning health outcomes, including immune system dysfunction, hormone disruption, developmental impacts, and potential carcinogenic effects. The Food Packaging Forum provides a comprehensive database of evidence related to the risk of PFAS in food packaging. While exposure pathways are multiple, food contamination represents a significant route of human exposure, with migration from packaging materials contributing to this burden.
  2. From a regulatory efficiency perspective, substance-by-substance risk assessment cannot practically keep pace with the thousands of PFAS compounds that may be used in commerce. By the time individual compounds are thoroughly assessed, new ones may have already entered the market as substitutes.
  3. With commercially viable alternatives already available for food packaging applications, a precautionary ban across the entire group of PFAS represents a proportionate and economically justifiable approach to reducing unnecessary exposure to these persistent chemicals.

Question 11. Is there any regulatory divergence across the UK in terms of PFAS? If so, what are the implications, and is there a need for a more joined-up approach?

  1. Consumer protection standards relating to PFAS in products, including food packaging, lack uniformity across the UK. This creates particular challenges for businesses operating across internal UK borders, who may need to comply with different requirements depending on where products are sold.
  2. A harmonized UK-wide approach to PFAS in food packaging would benefit all stakeholders by creating regulatory clarity, ensuring equivalent public health protection across all regions, and reducing compliance burdens for businesses operating throughout the UK. While respecting devolved authorities' rights to set appropriate standards, a coordinated framework would improve overall effectiveness of PFAS management.

Question 12. How do other jurisdictions around the world, including the EU and US, regulate PFAS use and disposal, and what lessons, if any, can the UK learn?

  1. The European Union has taken leadership through its Packaging and Packaging Waste Regulation (PPWR), which establishes a comprehensive ban on all PFAS in food contact packaging (Article 5). The UK can look to adopt a similar approach, as set out below. 
  2. PFAS Limit Values

From August 12, 2026, packaging placed on the EU market must not exceed the following PFAS concentration thresholds:

○         25 parts per billion (ppb) for any single PFAS detected via targeted analysis (excluding polymeric PFAS)

○         250 ppb for the sum of PFAS detected via targeted analysis (excluding polymeric PFAS)

○         50 parts per million (ppm) for total PFAS, including polymeric PFAS

These thresholds apply to food-contact packaging and are measured using targeted analytical methods.

  1. Definition of PFAS

For the purposes of PPWR, PFAS are defined as substances containing at least one fully fluorinated methyl (CF₃-) or methylene (-CF₂-) carbon atom, consistent with the OECD definition and international scientific consensus.

This definition effectively bans the entire group of PFAS substances, avoiding the need to regulate thousands of PFAS compounds individually.

  1. Enforcement and Industry Impact

○         Packaging exceeding these PFAS thresholds will be banned from the EU market.

○         Manufacturers must ensure compliance by reformulating materials and verifying PFAS content through appropriate testing.

Conclusions and Recommendations

  1. We strongly recommend the implementation of a complete ban on PFAS in all food contact materials in the UK. The unique characteristics of PFAS chemicals—extreme persistence, mobility, bioaccumulation potential, and emerging evidence of health effects—warrant precautionary action to prevent continued environmental contamination and human exposure. The existence of commercially viable alternatives makes such restrictions both practically achievable and economically justified.
  2. With the EU already published a ban from 2026, the UK is at risk of falling behind and become a "regulatory havens" with less stringent controls, where the distribution of packaging containing PFAS might concentrate.
  3. We recommend adoption of a group-based regulatory approach rather than attempting to assess and restrict PFAS on a substance-by-substance basis. This approach recognises the fundamental similarities in environmental behavior across this chemical class and prevents regrettable substitution where one restricted compound is simply replaced with a similar alternative.
  4. The urgency of action on PFAS in food packaging is clear. By implementing comprehensive restrictions now, the UK can protect public health and environmental quality while creating economic opportunities through leadership in safer alternatives development.

 

May 2025

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