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AI ARSNgKA HEAL HrEoALrTH AN (Eg CHEMTosrJB ve wesasaszs-cansaon CO) =cognac . Qsunp= On behalf of: Tek Forbrugerradet [obs )nratiions B [---- PcNommissioonntael-- rs Srl sides DComT mis SToAES Brussels, 2TM June 2021 Re: Civil society findings of widespread presence of harmful chemicals PFAS widespread in food packaging and request for a meeting DGeeaarrVCioemrmeissisdoneanrtsTKmyaaridmeann,sS,nkevicu, Breton, oWevtshhadnraeboaudhengeasvaatinonsofaprer iamntgtpoeoanrneddecformmpayonus(hPo9u6t)thie lfedn cfomos eC saSan o,attemeC nageapbotT3 a iCoynT 0thBT vapern orsem-- CE In our study "Throwaway Packaging, Forever Chemicals: European-wide survey of PFAS in disposable ima a cad mn a Seva Panga Se The Cee food packaging and tableware", single use paper, board and moulded plant fibre food peo packaging aTnhde Nefetvhferrliaenedsm1,eahnfedortmheoevmUenrietfeeedmcKtiiongawdoamu y. oItf9sae uggmesgtsHiaghhwepihdeeatperrensieenccneheamnhidcuasslea.ofePnFAeaSlosu5sb4sthanocfeoswod-- rata. Cur ings cdethefollowing + parriaaacekowigdmeglvyousmedpinoppoSsesentfoodspaackaginbg arndea.bove in Europe.Tis ues Traces of PFAS were detected in all samples selected for lab analysis demonstrating the pervasive contamination of both production and supply chains for paper and board food packaging with PFAS chemicals, which is a barrier to a clean and safe circular economy. Intentional PFAS treatment was confirmed in 32 out of the 42 samples sent to the laboratory for analysis. The highest concentrations were consistently found in moulded plant fibre products, which are often advertised as biodegradable or compostable and are getting increasingly popular to replace single use plastic items. The PFAS present in some of the samples analysed showed the potential to impair thyroid activity, warranting further investigation of potential endocrine disrupting properties. In Denmark, which is the only country that had introduced a ban on PFAS in food packaging, none of the sampled McDonald s French bags exhibited any PFAS treatment in contrast to samples of the exact same items in other countries, for instance the Czech Republic and the United Kingdom. This shows the success of the Danish regulatory effort on PFAS and the related swift adaptation from market players to find safe substitutes. However, this also highlights the lack of harmonised protection for citizens across the Europe. Because all PFAS compounds are very persistent, their widespread presence in disposable items produced in high volumes and with a very high turnover rate is of great concern. Our findings confirm an accelerating trend of PFAS accumulation in our environment, which endangers human health and wildlife as well as the achievement of a clean circular economy. This is in contrast to the objectives set in the EU Green Deal and the CSS, which includes specific actions to address PFAS contamination in Europe. In our view, PFAS treatment in food packaging and tableware is a typical illustration of uses that are not necessary and can be substituted either through safer treatment of disposable packaging or through the mainstreaming of collection and reuse systems of durable food containers in the food distribution sector. This fits perfectly in the ongoing Commission reflections about criteria for essential/non-essential uses as well as safe-and-sustainable-by-design chemicals. In the context of the Commiss commitments under the EU Chemicals Strategy for Sustainability, we urge you to support the swift preparation of the REACH restriction on all non-essential uses of PFAS and to proceed swiftly with the development of the promised criteria for essential/nonessential uses as well as for safe-and-sustainable-by-design chemicals. We would therefore like to request an online meeting with you in order to present our findings to you and to have an exchange about their important implications. We thank you for considering our request and we look forward to exchanging with you at your earliest convenience. Yours sincerely, Health and Environment Alliance (HEAL) Anika CHEM Trust International Pollutants Elimination Network (IPEN) On behalf of: BUND - Friends of the Earth Germany Forbrugerridet Tank Kemi - Danish Consumer Council Gnrations Futures Tegengif Attachments: Fduilslproespaobrlte,fTohord opwacakwaagyiPngacaknadgitanbgl,eFwoarreeverChemicals:European-wide surveyofPEAS in - Executive Summary with recommendations