Amid escalating tensions in the Middle East, energy and chemical supply chains are facing heightened uncertainty again.

Volatile crude oil prices and rising raw material costs have brought "safety, compliance and sustainability" back to the forefront of unavoidable priorities for the global manufacturing industry.

In this chain reaction extending from energy to materials, the food packaging sector is also undergoing a profound transformation, with a once widely relied-upon class of functional chemicals now under renewed scrutiny.

PFAS (per- and polyfluoroalkyl substances) have long been used in food contact materials due to their excellent water and oil repellency. However, with advances in toxicological research and tightening global regulatory oversight, their potential health and environmental risks are being systematically evaluated, and related applications are facing reassessment.

As "performance advantages" are no longer the sole consideration, the industry is confronted with a more pragmatic question: how to strike a new balance among safety, compliance and functionality?

Recently, Adsale Plastics Network interviewed Zhong Huaining, Director of the National Reference Laboratory for Food Contact Materials (Guangdong). He offered an in-depth analysis of the PFAS transition from the perspectives of regulatory trends, risk perception and alternative pathways.

Zhong Huaining, Director of the National Reference Laboratory for Food Contact Materials (Guangdong)

1. PFAS takes center stage: Four drivers of industry change

Zhong pointed out that the rising attention on PFAS mainly driven by four key factors:

• Sharp increase in PFAS-covered substances: The Organisation for Economic Co-operation and Development (OECD) updated its definition of PFAS in 2021, increasing the number of regulated substances from over 4,000 to nearly 10,000. Specifically, the OECD significantly expanded the scope of PFAS, defining PFAS as fluorinated substances that contain at least one fully fluorinated methyl（–CF₃）or methylene carbon atom（–CF₂–）, with no hydrogen, chlorine, bromine or iodine atoms attached to these carbon atoms. This widely recognized definition has considerably expanded the range of PFAS, increasing the number of covered substances from more than 4,000 to nearly 10,000.

• Regulations are becoming increasingly stringent: EU, France, Canada and other countries have successively introduced regulations, shifting PFAS control from individual substances to broad restrictions or bans, while commonly adopting total fluorine or total organic fluorine thresholds (Total fluorine refers to the content of all fluorine elements or fluorine present in organic form). In particular, the EU’s PPWR sets limits on both total PFAS content and individual PFAS substances, thereby increasing the complexity of compliance for companies.

• Rethinking the risks of PFAS alternatives: New toxicological studies show that short-chain PFAS, once regarded as safe alternatives to carcinogenic PFAS such as PFOA and PFOS, are not absolutely safe. Their toxicological effects affect multiple systems including immunity, nerves, reproduction and the liver. Based on the toxicity of short-chain PFAS and the bioaccumulation of their metabolites, the U.S. Food and Drug Administration (FDA) has revoked 35 PFAS-related food contact notifications, including one for 6:2 fluorotelomer alcohol (6:2 FTOH), a short-chain PFAS. This indicates that conventional substitution strategies are facing serious challenges.

• Growing challenges in testing and traceability: A large number of PFAS substances lack reference standards and effective testing methods, posing new technical challenges for detection, traceability, and regulatory control.

2. PFAS in food contact materials: Applications and hidden risks coexist

PFAS are primarily used in two types of food contact materials:

• Paper products: Including disposable paper tableware, molded pulp tableware, and greaseproof paper, where fluorinated copolymers are used to achieve oil and water resistance.

• Coatings and processing aids: Such as non-stick pan coatings and mold release agents.

In addition, certain fluorinated rubbers and plastics may also contain PFAS.

However, these materials pose three major safety risks during use:

• PFAS can easily migrate into food under high-temperature or high-fat conditions.

• Excessive human exposure may lead to reproductive and developmental toxicity, immunotoxicity, liver damage, endocrine disruption, and potential carcinogenic effects.

• When food packaging waste is incinerated or landfilled, PFAS can contaminate soil and groundwater, causing long-term ecological damage.

3. Domestic and international regulations: Growing compliance pressure

As regulations and major brand owners tighten their control over PFAS, packaging manufacturers are facing mounting compliance pressure.

The EU's Packaging and Packaging Waste Regulation (PPWR) requires that, from August 12, 2026, the concentration of any individual PFAS measured by targeted analysis shall not exceed 25 ppb, and the total target PFAS content shall not exceed 250 ppb, with a total fluorine content of 50 ppm serving as the threshold for proof of fluorine origin.

In the US, several states have enacted legislation targeting PFAS in food packaging, comprehensively prohibiting the "intentional addition" of any PFAS in food contact materials.

As a signatory to the Stockholm Convention, China currently adopts a targeted control approach based on a priority list of new pollutants. At the same time, the industry is strengthening self-discipline through group standards, further driving product compliance and safety.

4. Transformation: How to implement alternatives to hazardous PFAS?

To achieve this transition, companies must address a number of challenges, including performance, cost, safety and regulatory compliance.

At present, non-fluorinated alternatives still generally fall short of PFAS in key properties such as water resistance, grease resistance and high-temperature stability. In addition, these alternatives tend to be more costly, while the potential toxicological risks of certain substitutes should not be overlooked.

Furthermore, new raw materials and new chemicals are often not yet permitted for use in food contact materials, making regulatory approval another critical concern.

Two main technical pathways are considered viable:

• Physical barriers: Cellulose-based alternatives such as natural greaseproof paper as well as composite structures incorporating plastic coatings or aluminum layers.

• Chemical substitutes: R&D focused on silicone polymers, acrylic polymers and bio-based coatings.

To assess the safety of these alternatives, Zhong recommends a multi-dimensional evaluation strategy that combines "total fluorine screening + targeted confirmation + non-targeted analysis as a safeguard", to achieve full coverage of substances of high concern.

5. Corporate transition: Several critical issues must not be overlooked

In promoting PFAS substitution technologies, Zhong pointed out that companies need to pay particular attention to the following issues:

• Background contamination in the supply chain: Auxiliary materials, process water and production environment pollution may lead to excessive fluorine in finished products.

• Compliance risks of alternative products: Many new alternatives lack complete toxicological data and have not been officially approved for food contact applications, posing compliance risks in countries operating under positive list systems.

• Environmental liabilities after disposal: Although some alternatives are labeled "compostable", they may still contain PFAS, which could cause environmental contamination and subsequent litigation once released into the environment.

• Insufficient supply chain transparency: With multiple definitions of PFAS, suppliers hold varied understandings of "PFAS-Free", leading to information barriers along the value chain. Incomplete material disclosure directly impacts final compliance.

6. Future outlook: Tighter regulation, with technological innovation as the key

Director Zhong predicted that over the next 3–5 years, the PFAS transition in food contact materials will be shaped by three major trends:

• Upgraded regulatory policies: Controls will shift from restricting specific substances to broad restriction or ban of all PFAS, except for essential and critical applications.

• Stricter testing standards: The adoption of total fluorine / total organic fluorine thresholds combined with PFAS content limits will become a global consensus, requiring more accurate and sensitive testing technologies.

• Adjustments in circular economy: Fluorine-containing waste paper may become a "risk asset". The industry should accelerate the transition toward virgin pulp systems and PFAS-free production.

7. Expert recommendations: Five measures to drive the transition

To support the industry in achieving a smooth PFAS transition, Zhong put forward five recommendations:

• Establish a multi-dimensional, tiered control strategy based on total fluorine screening + non-targeted analysis + targeted confirmation.

• Proactively screen for fluorine-containing components in the supply chain to prevent contamination from inorganic fluorine and non-intentionally added fluorine, while developing high-performance alternatives that meet performance requirements.

• Take an active role in standard-setting to voice rational industry needs and actual production conditions, making standards more scientific and operable.

• Conduct timely new substance notifications for alternative products to avoid unauthorized use of unapproved chemicals.

• Develop tailored PFAS compliance strategies according to the regulatory requirements of different target markets.

Conclusion: An inevitable path toward high-quality development

Our conversation with Zhong makes one thing clear: PFAS substitution has become a mainstream direction for the food contact materials industry in its pursuit of high-quality development. This transition is not only about regulatory compliance, but also a vital reflection of sustainable development and corporate social responsibility.

Looking ahead, the industry must act proactively and embed rigorous management across the entire value chain from raw materials and production to compliance testing, thereby achieving high-quality development that is quality-controlled, compliant, safe, and environmentally friendly.