Document NGrM69Lbpqg25QM3MbQddJ2dy

AL ARNIKA HEAL ge Eg crenre [IE Bl ne rrsnareasan carson OF wma Ee Qsunp ne Forbrugerradet ganerratioens: I oteasnoness To: European Commission Brussels, 2 June 2021 Re: Civil society findings of widespread presence of harmful chemicals PFAS widespread in food packaging and request foar meeting esCeopmreesesnTens,Soc, con, T tende rss, eair n ou ne x n fors you soi ehlesey Joint study about the presence of per- and polyfluorinated compounds (PFAS) in food contact forSustainability (CSS). ies ereeise t oeeoeermeetmweoM aovrgvewo a her eht eo et ot packaging. Pecsforbeisnttyboownivptoiseeriordimcnhoindyetn pe Ts chs x 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. x Intentional PFAS treatment was confirmed in 32 out of the 42 samples sent to the laboratory for analysis. x 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. x The PFAS present in some of the samples analysed showed the potential to impair thyroid activity, warranting further investigation of potential endocrine disrupting properties. x In Denmark, which is the only country that had introduced a ban on PFAS in food packaging, none of the sampled McDonald's French fries' 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 Commission's 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 EnvironmentAlliance (HEAL) Amika CHEMTrust International Pollutants Elimination Network (IPEN) Onbehalfof: `BUND --FriendsoftheEarthGermany. Forbrugerrdet Tonk Kemi - Danish Consumer Council `Gnrations Futures Tegengit Atta~chmeFnutls:report, Throwaway Packaging, Forever Chemicals: European-wide survey of PEAS in disposable food packaging and tableware - Executive Summarywith recommendations