Denmark Bans PFAS in Food Contact Articles (Paper & Cardboard)

22 Jun 2020

In September 2019, the Danish Ministry of Environment and Food announced its intention to ban per- and polyfluoroalkyl substances (PFAS, also known as PFAS chemicals) in food contact paper and cardboard materials and articles, which made Denmark the first country in the world to ban the entire group of PFAS in a product type.

In April 2020, the Danish Veterinary and Food Administration published a Guideline on Fluorinated substances in paper and cardboard food contact materials (FCM). PFAS can create a grease and water repellent effect on paper and cardboard materials, which constitute a large group of chemical substances that are persistent and some of them might accumulate in humans and animals. Quite a few substances are suspected to be carcinogenic, harmful to the immune system and endocrine disrupters.

On May 27, 2020 Denmark published Order No. 681 of May 25, 2020 ‘Executive Order on Food Contact Materials and Penal Code for Violation of Related EU Acts’ in its Official Gazette (Lovtidende A) to prohibit PFAS chemicals in food contact paper and board materials and articles, which repeals Order No. 1248 of October 30, 2018 on ‘Food Contact Materials’.

This new Order contains, inter alias, several important changes:

Addition of definition for paper and board – materials and articles made of cellulose-based natural fibres from virgin and recycled sources, and may contain artificial fibres, functional additives, processing agents, polymeric binders, inks, lacquers, coatings and adhesives
Prohibiting PFAS in food contact paper and board materials but these are allowed subject to having a functional barrier in the product to prevent PFAS migration into food
Allowing a transitional period for PFAS-containing food contact paper and board materials and articles that are placed on the market before the effective date of July 1, 2020. Food contact paper and board materials and articles which met the general safety requirements in Regulation (EC) No 1935/2004 but above-mentioned PFAS prohibition requirements and were placed on the market before July 1, 2020, may remain on the market until stocks are exhausted
Editorial changes and deleting Appendix 7 ‘List of Appendices’

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