PFAS Grease-Proofing Leaves U.S. Food Packaging (2024)

Table of Contents

1. What the FDA Announced in February 2024
2. What PFAS Are and Where the Grease-Proofers Were Used
3. Why the FDA Singled Out Paper Grease-Proofers
4. The 2020 Safety Assessment and the Voluntary Commitments
5. The March 2024 Rule on Retiring Unused Authorizations
6. The March 2024 Import Alert for Chemical Contaminants
7. The November 2024 Request for Information on PFAS in Seafood
8. What the 2024 Actions Do Not Do
9. Dates and Legal Status as of 11 October 2026
10. How the 2024 Actions Fit the FDA’s Earlier PFAS Work
11. Primary Documents
12. Key Research Papers
13. Connections

1. What the FDA Announced in February 2024

The FDA news release of 28 February 2024, “FDA, Industry Actions End Sales of PFAS Used in US Food Packaging,” is attributed to the agency’s Deputy Commissioner for Human Foods. It states that “grease-proofing materials containing per- and polyfluoroalkyl substances (PFAS) are no longer being sold for use in food packaging in the U.S.” and that “the major source of dietary exposure to PFAS from food packaging like fast-food wrappers, microwave popcorn bags, take-out paperboard containers and pet food bags is being eliminated.”

A constituent update issued by the FDA’s Human Foods Program the same day gives the detail. It says the announcement marks “the completion of the voluntary market phase-out” of these substances on food packaging paper and paperboard, and that this “eliminates the primary source of dietary exposure to PFAS from authorized food contact uses.” Two groups of manufacturers were involved:

• manufacturers that had given the FDA written commitments in 2020, after the agency’s post-market safety assessment, to stop selling grease-proofing substances containing certain types of PFAS for U.S. food-contact use; the announcement marks “the fulfillment of these voluntary commitments”;
• other manufacturers, whose grease-proofing substances contained different types of PFAS, which the FDA “has confirmed” also voluntarily stopped sales for U.S. food-contact use.

The February step was a market exit by manufacturers, confirmed and announced by the FDA. It was not a rule, an order or a ban; the formal legal step, retiring the authorizations themselves, followed in January 2025 (section 9). The constituent update adds that the FDA is “working towards a validated analytical method” that would let it monitor the market for these substances in food packaging.

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2. What PFAS Are and Where the Grease-Proofers Were Used

The press release describes PFAS as “a diverse group of thousands of chemicals that resist grease, oil, water and heat,” and states that “exposure to some types of PFAS have been linked to serious health effects.” The November 2024 Federal Register notice on seafood is more specific: PFAS “do not easily break down, and some types have been shown to accumulate in the environment and in our bodies,” and exposure to certain types “has been linked to serious health effects, including hepatic, cardiovascular, immune, and developmental effects,” citing assessments by the Agency for Toxic Substances and Disease Registry and the Environmental Protection Agency.

A food contact substance, in the terms the FDA uses, is a substance that becomes part of a material used to make, pack, package, transport or hold food, without being meant to have any effect on the food itself. A grease-proofing agent is one such substance: according to the constituent update, these agents are applied to paper and paperboard packaging “to prevent the leaking of grease and oil, and for water-resistant properties.” The PFAS-containing versions were applied to:

• fast-food wrappers;
• microwave popcorn bags;
• take-out paperboard containers;
• pet food bags;
• “other similar types of packaging.”

The original commitment letters allowed up to 18 months from each manufacturer’s last date of sale for paper and paperboard already made with these substances to be used up. The constituent update states that “most of the companies have exited the market prior to their original phase-out date.”

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3. Why the FDA Singled Out Paper Grease-Proofers

The FDA’s page “Authorized Uses of PFAS in Food Contact Applications” says that since the 1960s the agency has authorized specific PFAS-containing substances for food-contact use, and that these uses “generally fall into four application categories.” It states that, of these, current data indicate “only paper and paperboard agents would result in dietary exposure to PFAS that may result in a potential safety concern.” Its explanation turns on how much of each material can migrate (move) from the packaging or equipment into food:

• Non-stick coatings on pots and pans. The PFAS molecules are polymerized (joined into large molecules) and baked onto the cookware at very high temperatures, which vaporizes off virtually all the smaller, migratable molecules. The FDA says studies show negligible amounts can migrate to food.
• Rubber O-rings and gaskets in food-processing equipment. The polymers are further cross-linked into a resin; the FDA says this process removes virtually all the smaller molecules, leaving negligible amounts able to migrate.
• Manufacturing aids added to other food-contact plastics. The FDA says the amounts used are so small that only negligible amounts can migrate.
• Grease-proofers on paper and paperboard. Here the PFAS are not polymerized but attached as smaller “sidechains” to other polymers, and the coating is applied at lower temperatures that do not drive off residual small molecules. “Under certain conditions, the smaller PFAS ‘sidechain’ can detach,” the FDA writes, so there was “potential for PFAS to migrate to food at levels that may result in a potential safety concern.”

The same page adds two points about testing. PFAS can turn up in packaging as an impurity or as an environmental contaminant — for example from contaminated water used in paper manufacturing — and these occurrences are not authorized uses. And general methods such as total fluorine analysis measure fluorine only, so they “cannot discern between the presence of PFAS or the presence of other non-concerning fluorine containing substances.”

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4. The 2020 Safety Assessment and the Voluntary Commitments

The FDA page summarizes the path to the phase-out. In the spring of 2020 the agency published findings from its review of newly available data on a subset of PFAS containing 6:2 fluorotelomer alcohol (6:2 FTOH), a six-carbon (“short-chain”) PFAS compound. Those findings “raised safety questions for exposure to 6:2 FTOH from the use of this subset of PFAS as grease-proofers in paper food packaging,” and the FDA then worked with industry to reach voluntary market phase-out agreements for all grease-proofers containing 6:2 FTOH.

The FDA states that this work, combined with its efforts in the 2010s on another subset known as “long-chain” PFAS, “removes all PFAS grease-proofers with known safety concerns from the market.” The makers of the remaining PFAS grease-proofers that were still authorized “voluntarily stopped selling them for non-safety reasons.”

The press release credits FDA research for the outcome: “The research FDA scientists conducted and published played a large part in helping the agency obtain commitments from manufactures to voluntarily phase out the use of these substances.” The FDA page lists that published work, including studies by agency scientists on how 6:2 FTOH and its breakdown products behave in the body; three of those studies are in the Key Research Papers list below. The release also notes that “assessing progress of these efforts takes time,” because industry was implementing changes and “there are lags in data reporting.”

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5. The March 2024 Rule on Retiring Unused Authorizations

Most PFAS grease-proofers were authorized through food contact notifications (FCNs). The FDA page explains that since 1999 food-contact authorizations have come to the agency mainly in this form, that each FCN is specific to one manufacturer or supplier, and that a manufacturer must show “a reasonable certainty of no harm from the intended use.” Under the Federal Food, Drug, and Cosmetic Act, as the FDA’s January 2025 notice summarizes it, a food additive (which includes a food contact substance) is deemed unsafe unless its use conforms to a regulation or is covered by an effective FCN.

Until 2024 the FDA’s rules let it declare an FCN “no longer effective” only on safety grounds. On 22 March 2024 the agency published a final rule, “Food Additives: Food Contact Substance Notification That Is No Longer Effective” (89 FR 20306, Docket No. FDA-2021-N-0403), effective 21 May 2024. It amended 21 CFR 170.105 to add reasons other than safety, chief among them abandonment: the manufacturer or supplier “has ceased or will cease” producing, supplying or using the substance for its authorized use. The rule also gives the manufacturer an opportunity to respond before the FDA makes such a determination, and it lets the FDA set a separate compliance date so that existing stocks can clear the market. The rule does not mention PFAS by name; its use for the grease-proofers came in the January 2025 notice, which cites it as the basis.

The rule states that the FDA would not declare an FCN abandoned if a manufacturer only temporarily stops production and says it intends to resume, and that the agency may decline an abandonment request where a safety concern would be better addressed through a safety determination.

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6. The March 2024 Import Alert for Chemical Contaminants

On 20 March 2024 the FDA issued Import Alert 99-48, “Detention without Physical Examination of Foods Due to Chemical Contamination.” An import alert tells FDA field staff that certain imported products may be held at the border. “Detention without physical examination” (DWPE) means a listed firm’s shipments can be detained without the FDA first sampling each one. According to the constituent update, the alert gives the FDA the ability to help prevent entry of human foods found to be contaminated with “a broad range of human-made chemicals including benzene, dioxins and polychlorinated biphenyls (PCBs), and per- and polyfluoroalkyl substances (PFAS), among others.”

The update describes how the FDA decides whether a contaminant level makes a food adulterated: case by case, considering whether an action level or tolerance exists, how much of the food people typically eat, the level detected and the toxicity of the specific contaminant. Specific firms and products found with levels that may pose a risk can be placed on the alert; to be removed, a firm must give the FDA evidence that it has resolved the conditions behind the violation.

The update cites a 2022 targeted FDA survey of 81 retail seafood samples — clams, cod, crab, pollock, salmon, shrimp, tuna and tilapia, most of them imported — which found that estimated exposure to perfluorooctanoic acid (PFOA), a type of PFAS, from certain samples of canned clams from China “is likely a health concern.” It says the FDA planned an additional targeted survey of molluscan shellfish in 2024 and that the new alert “could be used to refuse entry of foods like seafood contaminated with PFAS.”

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7. The November 2024 Request for Information on PFAS in Seafood

On 20 November 2024 the FDA published “Per- and Polyfluoroalkyl Substances in Seafood; Request for Information” in the Federal Register (89 FR 91765–91769, Docket No. FDA-2024-N-4604). The Federal Register is the U.S. government’s daily journal of agency notices and rules; a docket is the public file, identified by number, in which the documents and comments for one action are kept. The notice’s stated purpose is to “help fill data gaps that remain regarding” PFAS in seafood and to inform “future activities to reduce dietary exposure to PFAS that may pose a health concern.” Comments were due 18 February 2025.

The background the notice gives:

• Since 2019 the FDA has tested samples from its Total Diet Study. Of 810 food samples analyzed, PFAS were detected “at relatively low levels” in 23, and 19 of those 23 were seafood. The FDA determined that none of these seafood samples had PFAS levels that would be a human health concern, but writes that its testing “indicates that seafood may be at higher risk for environmental PFAS contamination compared to other types of food.”
• In 2021 and 2022 the FDA collected 81 further samples of the most commonly eaten seafood in the United States — clams, cod, crab, pollock, salmon, shrimp, tilapia and canned tuna, most of them imported. Based on the PFOA levels in canned clams, the FDA concluded that eating the canned clams sampled from China was likely a human health concern, and the notice records that two voluntary recalls of processed clams from China followed.
• For the notice, “seafood” covers fresh- or saltwater finfish, crustaceans, other aquatic animal life other than birds or mammals, and all mollusks intended for people to eat.

The questions fall into four groups: (1) PFAS concentrations in seafood, including species, harvest location, wild or farmed, raw or processed, and which tissues were tested; (2) PFAS in the environment where seafood is grown or harvested, such as water and sediment; (3) PFAS in the water used to process seafood; and (4) mitigation strategies, such as changing or closing harvest areas, processing only tissues found not to accumulate PFAS, depuration (holding shellfish in controlled conditions so impurities are eliminated), and whether PFAS testing is being added to seafood hazard-control (HACCP) plans. The notice asks for results where no PFAS was detected as well, because “information about samples where no PFAS was detected is just as important.” Background on one of the fish named in the surveys is on the Salmon page.

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8. What the 2024 Actions Do Not Do

• They do not end every authorized PFAS food-contact use. The FDA page continues to list non-stick cookware coatings, processing-equipment gaskets and O-rings, and manufacturing aids as authorized uses, from which it says only negligible amounts migrate to food. The phase-out concerned paper and paperboard grease-proofers only.
• The February 2024 step was not a rule. It was a voluntary market exit that the FDA confirmed and announced. The authorizations themselves stayed on the books until the FDA declared them no longer effective in January 2025.
• They do not address PFAS that reach food from the environment — through water, soil or the fish and shellfish that live in contaminated areas. That route is the subject of the seafood request for information, which gathers data and sets no limit.
• They set no PFAS limit for food. The seafood notice states that for chemical contaminants with no established action levels or tolerances, the FDA evaluates PFAS in food case by case.
• The import alert is not a ban on any food or country. It allows detention of shipments from specific firms and products found with levels that may pose a risk, and it provides a path for removal.
• They do not cover PFAS present as impurities or contaminants in packaging, which the FDA page says are not specifically authorized uses.

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9. Dates and Legal Status as of 11 October 2026

• 28 February 2024: FDA announces that PFAS grease-proofers are no longer sold for U.S. food-contact use (voluntary market exit).
• 20 March 2024: Import Alert 99-48 issued.
• 22 March 2024: final rule on FCNs that are no longer effective published (89 FR 20306); effective 21 May 2024.
• 20 November 2024: seafood request for information published (89 FR 91765); comment period closed 18 February 2025.
• 6 January 2025: the FDA’s notice “Food Contact Notifications That Are No Longer Effective” (90 FR 653, Docket No. FDA-2021-N-0403) declares 35 FCNs for PFAS grease-proofers on paper and paperboard no longer effective, “based on the abandonment of these uses.”

The January 2025 notice explains the process. Several manufacturers or suppliers had told the FDA, through their voluntary commitment letters, that they had stopped producing, supplying or using the substances for U.S. food contact. After the new rule took effect, the FDA contacted them, gave them an opportunity to respond, and received no response disagreeing with its findings. For 31 of the FCNs (the notice’s table 1), the FDA expected existing stocks to be exhausted already, given the end-of-sale dates the manufacturers had reported. For the other 4 (table 2), it set a compliance date of 30 June 2025 for stocks produced, supplied or used before 6 January 2025, a date it calls “protective of public health.” The notice adds that the determination does not prevent a manufacturer from submitting a new FCN for the same substance.

Status as of 11 October 2026: final. The PFAS grease-proofer authorizations covered by the 35 FCNs are no longer effective, and the 30 June 2025 compliance date for remaining stocks has passed; this completes the legal side of the phase-out. The seafood request for information closed in February 2025; a query of the Federal Register for FDA documents on PFAS through 11 October 2026 found no later notice or rule arising from it, and no document reversing or staying the January 2025 determination.

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10. How the 2024 Actions Fit the FDA’s Earlier PFAS Work

The FDA documents lay out a sequence:

1. Since the 1960s: the FDA has authorized specific PFAS-containing substances for food contact, for their non-stick and grease-, oil- and water-resistant properties.
2. Since 1999: new authorizations have come mainly as manufacturer-specific food contact notifications.
3. The 2010s: FDA efforts on “long-chain” PFAS grease-proofers, which the FDA page credits, together with the later work, with removing all PFAS grease-proofers with known safety concerns from the market.
4. Spring 2020: the FDA publishes its findings on 6:2 FTOH and obtains voluntary phase-out commitments.
5. January 2022: the FDA proposes the rule allowing FCNs to be retired for reasons other than safety (87 FR 3949), finalized in March 2024.
6. 2024: market exit announced (February), import alert (March), seafood request for information (November).
7. January 2025: the 35 grease-proofer FCNs are declared no longer effective.

The seafood notice places the work in a wider federal frame: it describes addressing Americans’ PFAS exposure as “a national priority” coordinated across several agencies, and notes that the FDA takes part in the Council on Environmental Quality-led Interagency Policy Committee on PFAS and an interagency research strategy team. The FDA’s later reviews of other food chemicals are covered on the site’s pages on the FDA’s 2025 moves on GRAS and chemical reviews and the 2026 proposal to make GRAS notices mandatory; the same year’s revocation of brominated vegetable oil is on the Brominated Vegetable Oil page.

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11. Primary Documents

1. U.S. Food and Drug Administration (2024). FDA, Industry Actions End Sales of PFAS Used in US Food Packaging. FDA News Release, 28 February 2024 — fda.gov press announcement
2. U.S. Food and Drug Administration, Human Foods Program (2024). FDA Announces PFAS Used in Grease-Proofing Agents for Food Packaging No Longer Being Sold in the U.S. Constituent Update, 28 February 2024 — fda.gov constituent update
3. U.S. Food and Drug Administration. Authorized Uses of PFAS in Food Contact Applications. Program page — fda.gov program page
4. U.S. Food and Drug Administration, Human Foods Program (2024). FDA Issues Import Alert for Food Products with Chemical Contaminants Including PFAS. Constituent Update, 20 March 2024 — fda.gov constituent update
5. Food and Drug Administration, HHS (2024). Food Additives: Food Contact Substance Notification That Is No Longer Effective; Final Rule. Federal Register 89:20306, 22 March 2024. Docket No. FDA-2021-N-0403 — FR Doc. 2024-05802
6. Food and Drug Administration, HHS (2024). Per- and Polyfluoroalkyl Substances in Seafood; Request for Information. Federal Register 89:91765–91769, 20 November 2024. Docket No. FDA-2024-N-4604 — FR Doc. 2024-27070 (official PDF, govinfo.gov)
7. Food and Drug Administration, HHS (2025). Food Contact Notifications That Are No Longer Effective; Notice. Federal Register 90:653, 6 January 2025. Docket No. FDA-2021-N-0403 — FR Doc. 2024-31692 (official PDF, govinfo.gov)

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Key Research Papers

1. Rice PA (2015). C6-Perfluorinated Compounds: The New Greaseproofing Agents in Food Packaging. Current Environmental Health Reports 2(1):33-40 — PubMed PMID: 26231240
2. Kabadi SV, Fisher J, Aungst J, Rice P (2018). Internal exposure-based pharmacokinetic evaluation of potential for biopersistence of 6:2 fluorotelomer alcohol (FTOH) and its metabolites. Food and Chemical Toxicology 112:375-382 — PubMed PMID: 29331735
3. Kabadi SV, Fisher JW, Doerge DR, Mehta D, Aungst J, Rice P (2020). Characterizing biopersistence potential of the metabolite 5:3 fluorotelomer carboxylic acid after repeated oral exposure to the 6:2 fluorotelomer alcohol. Toxicology and Applied Pharmacology 388:114878 — PubMed PMID: 31923437
4. Rice PA, Aungst J, Cooper J, Bandele O, Kabadi SV (2020). Comparative analysis of the toxicological databases for 6:2 fluorotelomer alcohol (6:2 FTOH) and perfluorohexanoic acid (PFHxA). Food and Chemical Toxicology 138:111210 — PubMed PMID: 32087313
5. Rice PA, Kabadi SV, Doerge DR, Vanlandingham MM, Churchwell MI, Tryndyak VP, Fisher JW, Aungst J, Beland FA (2024). Evaluating the toxicokinetics of some metabolites of a C6 polyfluorinated compound, 6:2 fluorotelomer alcohol in pregnant and nonpregnant rats after oral exposure to the parent compound. Food and Chemical Toxicology 183:114333 — PubMed PMID: 38061571
6. Schaider LA, Balan SA, Blum A, Andrews DQ, Strynar MJ, Dickinson ME, Lunderberg DM, Lang JR, Peaslee GF (2017). Fluorinated Compounds in U.S. Fast Food Packaging. Environmental Science & Technology Letters 4(3):105-111 — PubMed PMID: 30148183
7. Susmann HP, Schaider LA, Rodgers KM, Rudel RA (2019). Dietary Habits Related to Food Packaging and Population Exposure to PFASs. Environmental Health Perspectives 127(10):107003 — PubMed PMID: 31596611
8. Fenton SE, Ducatman A, Boobis A, DeWitt JC, Lau C, Ng C, Smith JS, Roberts SM (2021). Per- and Polyfluoroalkyl Substance Toxicity and Human Health Review: Current State of Knowledge and Strategies for Informing Future Research. Environmental Toxicology and Chemistry 40(3):606-630 — PubMed PMID: 33017053

Papers 1–5 are by FDA scientists; papers 3–5 appear in the list of scientific articles on the FDA’s “Authorized Uses of PFAS in Food Contact Applications” page. Paper 4 concluded that 6:2 FTOH is significantly more toxic in rodents than its breakdown product PFHxA, so that risk assessments using PFHxA data may underestimate the risk. Paper 6 measured total fluorine in about 400 fast-food packaging samples collected across the United States. Paper 7 reported associations in national survey data (NHANES 2003–2014) between eating microwave popcorn and higher blood levels of several PFAS; the authors note the association may reflect migration from popcorn bags.

PubMed Topic Searches

1. PubMed: PFAS migration from food packaging
2. PubMed: 6:2 fluorotelomer alcohol toxicokinetics
3. PubMed: PFAS in seafood and dietary exposure

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Connections

• FDA Actions of 2024
• FDA and Regulation
• PFAS: The “Forever Chemicals”
• Plastics and Packaging
• Phthalates
• Salmon
• Brominated Vegetable Oil Revocation (2024)
• Lead in Ground Cinnamon (2024)
• The “Healthy” Claim Final Rule (2024)
• FDA Moves on Self-Affirmed GRAS and Chemical Reviews (2025)
• Cesium-137 in Imported Shrimp and Spices (2025)
• FDA Proposal to Make GRAS Notices Mandatory (2026)

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