Clean packaging is moving to the top of the agenda for many brands and packaging converters because our industry needs to do the following...
Navigate legislation. Recent national legislation (Food Chemical Reassessment Act of 2021 aka FCRA and Toxic Free Food Act) is in process, and over 200 state policies have created a complex web that is tough for the industry to navigate.
Catch-up to current science. Only about 40% of approved food contact chemicals used in packaging have endured rigorous food safety assessments. Removing chemicals known to be cancerous, cause endocrine disruption, or bioaccumulate to be connected with your package or food can prevent a crisis. Phthalates, bisphenol-A (BPA), per- and polyfluoroalkyl substances (PFAS), and perchlorate Chemicals of Concern (COC) are the “tip of the iceberg.” A prioritized list of Tier 1, 2, and 3 chemicals provides focus.
Enable end-of-life viability. Packaging that’s safe to recycle, compost, and reuse is essential.
How get started.
Here are three recommendations to help you get started to cleaning up your packaging and removing COC.
Rec 1. Convey the Business case for assessing COCs.
The Value Chain is critical here since it begins with consumers, and removing COCs is an opportunity to build Consumer trust. Since 2017, consumers have ranked food chemicals as their top concern according to surveys conducted by International Food Information Council (IFIC) on Food and Health (FoodInsight, 2021). This concern is higher than for pathogens. Alignment with retailer demands that are now extending from their private label packaging can further strengthen the value of packaging. Additionally, eliminating COC in all global packaging operations enables ease of commerce.
Rec 2. Find out if COC are in your packaging and food.
Measuring COC in packaging and food in direct contact with packaging should be in all QA and packaging R&D budgets. To maximize impact, time, and money, use a 3-step process:
1. Identify Packaging with a high likelihood of containing these current COC. Importantly, this includes processing aids, inks, and adhesives. Letters from suppliers and their suppliers aid in this process.
2. Test packaging and food that are likely to contain these current COC. Importantly, incoming Packaging, as well as the finished packaged food, should be tested.
3. Act and plan forward. Replace these current COC and set up a protocol testing plan within standard operating procedures to ensure they do not reenter the packaging system.
Rec 3. Apply global and systems thinking to research.
First, already complete global can be applied worldwide to lower the costs of assessing the suitability of chemicals in direct contact with food. Then, a global approach can build on efforts such as the New FDA funding to address food chemicals; $7 million for Emerging Chemical and Toxicology Issues and $11 million for Maternal and Infant Health and Nutrition. Critically, the knowledge gap in the impact of chemicals as a function of age, gender, and chronic disease needs filling. Further, the classification of chemicals as a group - as was done with 4 of the 5 phthalates by the European Food Safety Authority (EFSA) – will provide a more accurate and lower cost impact assessment.
These three recommendations are lot to handle. However, it is essential to recognize that since we have “kicked the can down the road” on COC and Clean Packaging for many years, a high level of commitment and resources is needed now.
Claire Sand has 30+ years of experience in industry and academia. She’s owner of Packaging Technology and Research and Gazelle Mobile Packaging and an Adjunct Professor, CalPoly, Michigan State University, and the University of Minnesota. You can reach her at www.packagingtechnologyandresearch.com or [email protected].