PFAS its Restriction-CPC Certification_RoHS Testing_REACH Testing_CPSIA Testing

Recently, there have been increasing concerns regarding PFAS in the food packaging materials. PFAS is a group of man-made chemicals and is restricted in many countries.

PFAS (Per- and Polyfluoroalkyl Substances) are fluorinated organic chemicals containing at least one fully fluorinated carbon atom (i.e. at least one aliphatic -CF2- or -CF3- element). PFAS includes PFOA (Perfluorooctanoic Acid), PFOS (Perfluorooctane Sulfonate) and many other chemicals.

PFAS can impart oil, water, stain, and soil repellency, chemical and temperature resistance, friction reduction, and surfactant properties to products and have been widely used in the past.

PFAS has been found in food packaging materials (paper and paperboard for food packaging), consumer products including stain- and water-resistant fabrics and carpeting leather and apparel, non-stick cookware (e.g. Teflon), polishes, waxes, paints, cleaning products, and fire-fighting foams.

Certain PFAS, e.g. PFOA and PFOS have been found very persistent in the human body, and can lead to adverse health outcomes. Animal studies indicate PFOA and PFOS can cause reproductive and developmental, liver and kidney, and immunological effects. Both chemicals have caused tumours.

PFAS have been restricted in many major countries and regions, for example:

Country /Region	Regulation	Products Scope	Restricted PFAS and Limits	Applicable Date
China	Ministry of Ecology and Environment Notice No. 10 of 2019	Substances, products	(1) PFOS and its salts: shall not be used;(2) PFOSF: shall not be used.	26 March 2019
EU	POPs Regulation (Regulation (EU) 2019/1021)	Substances, mixtures, articles	(1) PFOA and its salts ≤ 0.025 mg/kg (25 ppb); (2) PFOA-related compounds ≤ 1 mg/kg (1000 ppb) (sum)	4 July 2020
EU	REACH SVHC	Substances, mixtures, articles	(1) Pentacosafluorotridecanoic acid: ≤ 0.1%; (2) Tricosafluorododecanoic acid: ≤ 0.1%; (3) Henicosafluoroundecanoic acid: ≤ 0.1%; (4) Heptacosafluorotetradecanoic acid: ≤ 0.1%; (5) APFO: ≤ 0.1%; (6) PFOA: ≤ 0.1%; (7) PFNA and its sodium and ammonium salts: ≤ 0.1%; (8) PFDA and its sodium and ammonium salts: ≤ 0.1%; (9) PFHxS and its salts: ≤ 0.1%; (10) PFBS and its salts: ≤ 0.1%; (11) 2,3,3,3-tetrafluoro-2-(heptafluoropropoxy)propionic acid, its salts and its acyl halides: ≤ 0.1%	Various, have applied
Denmark	Executive Order No. 681 of 2020	Food contact materials made of paper and board	PFAS: shall not be used.	1 July 2020
Canada	SOR/2012-285 and Amendment SOR/2016-252	Substances, products	(1) PFOS and its salts, its related substances: shall not be contained; (2) PFOA and its salts: shall not be contained; (3) C7-C8 PFAS: shall not be contained; (4) C9-C21 PFCAs and their salts: shall not be contained; (5) C8-C20 PFAS: shall not be contained.	1 January 2017
US Maine	06-096 C.M.R. ch. 890	Certain children’s products	PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant.	28 July 2020
US Washington	HB2658	Food packaging	PFAS: not intentionally added.	1 January 2022
US Washington	Washington CHCC (173-334 WAC)	Certain children products	(1) PFOA and related substances: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant; (2) PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant.	21 August 2011
US Vermont	Vermont CHCC (18 V.S.A. chapter 38A)	Certain children products	(1) PFOA: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant; (2) PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant.	10 June 2014
US Oregon	Oregon HPCCCH(OAR-333-016)	Certain children products	PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant.	1 January 2016
US New York	New York Environmental Conservation Law, Section 37 Title IX	Certain children products	(1) PFOA and related substances: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant; (2) PFOS and its salts: < PQL for intentionally added; or < 100 mg/kg (100 ppm) for contaminant.	1 March 2020
US New York	S.8817 and A.4739-C	Food packaging comprised of paper, paperboard, or other materials originally derived from plant fibers.	PFAS: not intentionally added.	31 December 2022
US Rhode	S.218	Food packaging	PFAS: not intentionally added	1 January 2020
US Massachusetts	S.1315 (SD 678)	Food packaging	PFAS: not intentionally added	1 January 2020
US California	Proposition 65	All products	(1) PFOA: not pose a significant risk; (2) PFOS: not pose a significant risk	10 November 2017
US California, San Francisco	San Francisco Ordinance No. 201-18	Food service ware	PFAS: not intentionally added	1 January 2020

Following restrictions on PFAS have been also proposed in major countries and regions, for example:

Country /Region	Regulation	Products	Proposed Restricted PFAS and Limits
EU	REACH Annex XVII	Substances, mixtures, articles	(1) C9-C14 PFCAs and their salts: < 0.025 mg/kg (25 ppb);(2) C9-C14 PFCA-related substances: ≤ 0.026 mg/kg (260 ppb) (sum)
US	Toxic in Packaging Model Legislation	Package or packaging components	PFSA not detachable.