compliance

PFAS Questions to Ask Your Food Packaging Supplier

Ask food packaging suppliers about PFAS with item-level declarations, FDA grease-proofing phase-out context, legacy-stock questions, and an evidence checklist.

Start with the item, not the slogan. Ask each supplier whether the specific paper or paperboard food contact item uses a grease, oil, or water barrier and whether any PFAS-containing grease-proofing substance is intentionally added. Request an item-level declaration, the regulatory basis the supplier relies on, and production dates for existing stock. File the evidence and re-ask after any material change. The FDA phase-out covers grease-proofing substances on paper and paperboard, so do not treat it as a blanket statement about all packaging.

What the FDA phase-out covers, and what it does not

The FDA has described a market phase-out of food contact substances containing PFAS that were used as grease-proofing agents on paper and paperboard food packaging. In February 2024, the agency announced that these substances were no longer being sold by manufacturers for food contact use in the U.S. market. In January 2025, the FDA said 35 food contact notifications related to these substances were no longer effective.

That scope matters for buyers. The action addresses a functional use, grease, oil, and water resistance on paper and paperboard, not every possible use of PFAS in every packaging material. A supplier statement that says the company is FDA compliant does not answer your item-level question. Ask instead whether the specific paper or paperboard component uses a grease-proofing substance and whether any PFAS-containing chemistry is intentionally added.

Why an item-level question beats a company-wide claim

A company may sell many packaging items. One item may use a coated paper with a barrier, another may use uncoated paper, and a third may use a molded fiber or plastic component. A company-wide PFAS-free statement can be true for one scope and silent on another. Buyers need evidence tied to the SKU, the material, and the intended food contact use.

Ask for the declaration to name the item, the paper or paperboard grade, any coating or barrier layer, and the intended use. If the supplier cannot name the item, the declaration is a starting point, not a closed file. Keep the response with the item record so a later reformulation does not erase the evidence trail.

Five questions to send in your supplier request

Keep the questions open enough that a supplier can answer with evidence rather than a slogan. Ask for a written response and attach it to the item record. If a supplier answers only that there is no PFAS without naming the item, send the request back with the item name and the barrier question highlighted.

  • Which components in this item are paper or paperboard, and which of those touch food directly?
  • Does any paper or paperboard component need a grease, oil, or water barrier?
  • Is any PFAS-containing grease-proofing substance intentionally added to the paper, coating, or barrier?
  • What is the regulatory basis for the supplier statement, including any food contact notification reference?
  • What production or supply dates apply to the stock you would ship, and how does the supplier manage older inventory?

How to read a material declaration without overreading it

Material declarations vary in scope. Some address intentionally added substances. Some address all substances present above a stated level. Some are based on supplier knowledge, and some are based on analytical screening. Those are different claims. Ask the supplier to state the basis and the boundaries.

A declaration that says no PFAS are intentionally added can be useful, but it does not by itself identify whether a grease barrier is present or whether a coating contains a substance the supplier did not add. A screening result can be useful too, but ask what the method detects and what it cannot identify. The FDA has also described a screening method for monitoring the market. That does not turn a supplier screen into a legal determination for your item.

A hypothetical evidence review with arithmetic

Imagine a buyer reviewing 24 paper and paperboard components across four suppliers. Fifteen components have a current, item-level declaration that names the paper or paperboard, identifies any grease, oil, or water barrier, and states whether a PFAS-containing grease-proofing substance is intentionally added. Nine components lack that evidence. The evidence gap is 9 divided by 24, or 37.5 percent.

Of those nine, four are direct food contact items that rely on a grease barrier. Those four represent 4 divided by 24, or 16.7 percent of the total, and they become the first review priority. This is an arithmetic planning estimate, not a test result, a compliance finding, or a market benchmark. The numbers are illustrative.

Decision table for common supplier answers

Use the table to sort responses into evidence states. The action column is a review step, not a legal conclusion.

Supplier responseWhat it establishesNext action
Written declaration says no PFAS are intentionally added to the named itemAn item-level statement, but only as strong as its scope and signerFile it and ask whether the declaration covers coatings, adhesives, and the paper barrier
Supplier cites a food contact notification or regulatory status but not the itemA regulatory reference, not proof for this SKURequest the item-level declaration and confirm the intended use
Grease barrier is present and the chemistry is unidentifiedAn unresolved functional useHold the item as unverified and request chemistry disclosure or a non-PFAS alternative
Stock was produced before January 6, 2025A possible legacy inventory questionRequest production and supply dates and the supplier's basis for handling legacy stock. Have qualified counsel check the applicable FDA notice and current obligations rather than inferring eligibility from the production date alone.
Supplier offers only an analytical screenA result whose evidentiary scope depends on the method, target analytes, reporting limits, and sampled materialAsk what was sampled, what the method detects, its reporting limits, and whether it identifies specific substances. Request supporting material or chemistry information where the result leaves gaps.

A practical checklist for the buyer file

This checklist is Teal's editorial planning framework. It helps organize questions and evidence; it does not replace legal review or the converter's instructions.

  • List every paper and paperboard component that touches food directly.
  • Mark each item that needs a grease, oil, or water barrier.
  • Request a declaration per item and per supplier site, not a company-wide statement.
  • Ask whether any PFAS-containing grease-proofing substance is intentionally added.
  • Ask for the regulatory basis the supplier relies on, including any food contact notification reference.
  • Ask for production dates and whether stock predates January 6, 2025.
  • Ask what analytical method was used, if any, and what it can and cannot identify.
  • Keep declarations, emails, and certificates in one evidence file.
  • Re-request evidence after any paper, coating, or supplier change.
  • Confirm channel and customer requirements in your own agreements.

Scope limits and what to confirm elsewhere

This guide is not legal advice and does not determine compliance for any product. The FDA sources cited address grease-proofing substances containing PFAS used on paper and paperboard food packaging. They do not establish that all PFAS are prohibited in all packaging, that a specific item is PFAS-free, or that a particular test result meets a legal standard.

State requirements, customer specifications, and retail channel rules can differ from the FDA action described here. Confirm those in your own agreements and with qualified counsel. Teal does not certify PFAS-free status or issue compliance determinations. If you need a supplier declaration for a Teal project, ask for it per item and keep the scope written.

Questions about PFAS grease-proofing declarations for paper food packaging

Does the FDA action mean all PFAS are banned in food packaging?

No. The FDA sources describe a market phase-out of grease-proofing substances containing PFAS used on paper and paperboard food packaging, and a determination that 35 related food contact notifications are no longer effective. They do not say every PFAS use in every packaging material is prohibited. Ask your supplier about the specific item and confirm other requirements in your own agreements.

Is a PFAS-free supplier certificate enough?

Treat it as one piece of evidence. Ask what item and materials it covers, who signed it, whether it addresses intentionally added PFAS in the paper, coating, and adhesive, and what declaration or test basis supports it. A certificate that does not name your SKU or define its scope leaves you with an open question.

What should I ask about packaging made before January 6, 2025?

Ask for production and supply dates, whether older stock remains, and the supplier's documented basis for handling it. FDA described a limited legacy-stock transition, but the excerpts cited here do not establish which specific items qualified. Have qualified counsel review the applicable notice and current obligations, and separately confirm customer requirements. A production date alone does not establish compliance.

Sources and further reading