Why PFAS is a packaging question
PFAS, per- and polyfluoroalkyl substances, are a large family of fluorinated chemicals. In food packaging they have been used to give paper, board and molded fibre resistance to grease and water, which is exactly what a burger wrap, a fried food box or a bagasse bowl needs. Concern about their persistence has led a number of US states to restrict PFAS in food packaging, and the restrictions fall mainly on the products buyers moved to when they left plastic: paper boxes, molded fibre and bagasse.
For a container program this means the paper and fibre parts carry a compliance question that the plastic parts do not. A kraft bakery box with a PET window, a click-lock takeout box in white card with a foil lining, or a molded fibre clamshell each need a PFAS position for every US state where they will be sold. The rules change and differ between states, so the summary below is a sourcing view; confirm the current position for your states with your test lab or counsel.
California AB 1200
California's AB 1200 has prohibited intentionally added PFAS in plant fibre based food packaging since 1 January 2023. Plant fibre packaging includes paper, paperboard and molded fibre such as bagasse. The law uses total organic fluorine as a screening measure, with 100 parts per million as the line above which PFAS are treated as present. For buyers, that gives a practical test: a total organic fluorine result below the line, together with a supplier statement that no PFAS are intentionally added, is the usual basis of the file for California.
The states with restrictions
At least 13 states restrict PFAS in food packaging in some form: New York, California, Washington, Colorado, Connecticut, Maryland, Minnesota, Hawaii, Oregon, Rhode Island, Vermont, Maine and New Hampshire. The scope varies. Some rules cover plant fibre or paper based packaging, others cover a wider set of materials; Vermont, Connecticut and Minnesota extend their rules to food packaging materials in general. Effective dates, definitions and reporting duties also differ. The table below is a planning summary, not a legal reading.
| Rule or group | Scope as summarised | What the file needs |
|---|---|---|
| California AB 1200 | Intentionally added PFAS in plant fibre food packaging, since 1 January 2023; 100 ppm total organic fluorine screening line | No intentionally added PFAS statement; total organic fluorine test |
| Vermont, Connecticut, Minnesota | Rules extend to food packaging materials in general | PFAS statement for paper and plastic parts alike |
| Other restricting states | New York, Washington, Colorado, Maryland, Hawaii, Oregon, Rhode Island, Maine, New Hampshire, scope per state | Statement and test per current state law |
| States without a specific rule | Federal food contact rules still apply | Supplier declarations as for any food contact item |
Because a national brand or marketplace seller rarely controls which state a parcel ends up in, most programs adopt the strictest applicable position for all US stock rather than run state-specific versions.
Which items in a range are affected
In a typical program the PFAS question concentrates on a few lines. Folding bakery and gift boxes in kraft, white card or white card with a foil lining from the Longgang printing cluster near Wenzhou are paper based. Click-lock takeout boxes from 350 to 2,880 ml and pizza boxes from 6 to 12 inches are paper based. Molded fibre and bagasse bowls are plant fibre. Clear windows on paper boxes, in PET or PVC, are plastic parts with their own food contact file. PP takeout boxes and starch and PP blend containers are plastic; they still need a PFAS position in the states whose rules reach all food packaging materials.
What to ask a partner plant
- A written statement that no PFAS are intentionally added to the item, its coatings or inks.
- A total organic fluorine test on the finished item from a third-party lab, for California and other states using a screening line.
- The name and type of any grease or water barrier used, and its supplier statement.
- Food contact documents for the paper item and, separately, for any plastic window or lining.
- Confirmation that the tested item matches the ordered item in board grade, coating and print.
Statements and reports are issued to partner plants or to your brand per project and verified by the desk. Lidwell does not hold them. Where the item changes, a new board, a new coating or a new plant, the desk asks for a new statement and, if needed, a new test.
An illustrative case
An illustrative example, anonymised: a bakery chain moving from plastic clamshells to kraft boxes with a clear window planned to sell in several states. The first quotes described the board as grease resistant without saying how. The desk asked each partner plant for the barrier type, a no intentionally added PFAS statement and a total organic fluorine result on the finished box. One plant could document all three; another could not name its coating supplier and was dropped from the shortlist. The window was specified in PET and filed separately as a plastic part. The result was one box specification for all US stock, with its documents tied to the board grade and print.
PFAS and compostable claims
Molded fibre and bagasse items are often offered as compostable. A compostable claim needs a certificate to EN 13432 or ASTM D6400 for the exact item and, in the US, qualified wording under the FTC Green Guides at 16 CFR 260.7. A PFAS statement does not support a compostable claim, and a compostable certificate does not answer the PFAS question. A fibre item sold in the US with a compostable claim needs both files; see compostable certification and molded fiber and bagasse boxes.
Planning a paper or fibre program
Total organic fluorine tests and barrier statements take time to collect, so they are scheduled with the samples. Printed paper boxes typically start at 5,000-10,000 pieces per design, with printed samples in 7-15 working days, confirmed in writing per program; see MOQ and lead time. The folding gift boxes page sets out board grades and window options, and the compliance guide lists documents by market. Send the item list and the states you sell into through the quote form.