IN Brief:
- More than 15,000 chemicals can be used in or be present in food-contact articles, while the researchers report major gaps in available safety data.
- The methodology identifies 38 priority structural groups and supports screening through the FCCprio and FCCgroup tools.
- Group-based assessment is intended to help identify problematic substitutions where individual chemical hazard data remain incomplete.
Food Packaging Forum Foundation researchers have proposed a group-based method for prioritising chemicals used in food-contact materials, addressing the difficulty of assessing thousands of substances one by one when hazard data remain incomplete. The peer-reviewed work was published on 1 September in Environmental Science & Technology alongside freely accessible screening tools.
More than 15,000 chemicals can be used to manufacture, or can be present in, food-contact articles including packaging and kitchenware. The researchers report that 87% lack adequate safety data, while 1,222 food-contact chemicals have already been identified as hazardous to human health. That disparity leaves a large number of substances for which regulatory or product-development decisions may have to be made with incomplete evidence.
The proposed method groups chemicals according to structural similarity rather than requiring every substance to accumulate a complete individual toxicological dataset before priorities can be set. Structurally related chemicals can share hazard characteristics, so groups containing a high proportion of known hazardous substances can be selected for closer assessment, restriction, substitution, or further testing.
The researchers identified 38 priority chemical groups. Examples include ortho-phthalates, per- and polyfluoroalkyl substances, organophosphates, isocyanates, and primary aromatic amines. Membership of one of those groups does not establish that every individual substance is hazardous; it flags a structural relationship that can justify additional scrutiny where substance-specific evidence is weak or absent.
Two practical resources accompany the research. The FCCprio List provides an evidence-based inventory of 1,222 known hazardous food-contact chemicals, while the FCCgroup application allows users to screen chemical inventories, check known hazard information, and assign substances to the defined structural groups. The underlying grouping definitions and mapping rules have also been published, providing a transparent basis for how chemicals are classified.
Material chemistry is already receiving greater scrutiny in food packaging as regulatory requirements extend further into formulation. The EU Packaging and Packaging Waste Regulation includes restrictions affecting PFAS in food-contact packaging, adding pressure to programmes that replace substances in coatings, adhesives, inks, polymers, and barrier materials. Group-based screening offers a way to examine whether a replacement is structurally close to another chemical already associated with hazard before a formulation is committed to commercial production.
That substitution problem is one of the practical issues identified by the researchers. Removing a restricted substance does not necessarily reduce risk if it is replaced by a closely related chemical with similar properties but substantially less hazard evidence. Screening by chemical family can expose those relationships earlier and help technical teams decide where more detailed toxicological, migration, or supplier data are needed.
Food packaging performance requirements can make substitution particularly difficult. Grease resistance, moisture control, oxygen barriers, heat sealing, printability, durability, and migration limits all influence material selection, while converters and food producers also need structures that run reliably through industrial filling and packing equipment. Changes towards no-PFAS-added food packaging formulations illustrate how restrictions can require work across whole material portfolios rather than the removal of a single ingredient.
Grouping does not replace migration testing, toxicological assessment, food-contact compliance, or the legal requirements attached to a particular material. Its purpose is closer to triage: chemical inventories can be screened to establish where evidence already indicates concern, where major information gaps remain, and where a proposed substitute resembles substances that warrant additional assessment.
The method can also add another layer to chemical-data management within packaging supply chains. Declarations of compliance and technical files are commonly organised around individual substances, materials, suppliers, and specifications. Structural grouping allows those inventories to be compared across chemical families, which may help identify clusters of concern when reviewing legacy formulations or assessing alternatives.
The scale of the underlying data gap remains the central constraint. The research does not claim that structural similarity provides a definitive safety assessment for an individual substance, and full testing remains necessary where required. Instead, the approach provides a way to decide which chemicals and substitutions deserve attention first when complete hazard information is unavailable for much of the food-contact chemical universe.
The researchers have made the FCCprio and FCCgroup resources publicly accessible alongside the published methodology. Their practical test will be whether regulators, packaging developers, and chemical suppliers can use the grouping system to reduce poorly evidenced substitutions while directing detailed assessment towards the chemical families carrying the strongest existing hazard signals.
