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Despite a clear legal prohibition of carcinogens in food, several are still permitted, posing a risk to Americans’ health.
By Maria Doa, Ph.D., Liora Fiksel and Emma Barrett
What’s new? A new EDF analysis has found that the Food and Drug Administration (FDA) allows 25 chemicals linked to cancer — or carcinogens — to be used in Americans’ food. These chemicals can be used across the food production chain as ingredients or processing agents, in packaging materials and more, putting the health of consumers and workers at risk.
Our analysis identified 8 known human carcinogens and 17 probable human carcinogens that the FDA allows for use in U.S. food products when they are present in small amounts in other ingredients or in food contact articles approved for use. All 25 substances are recognized as carcinogenic by the congressionally mandated 15th Report on Carcinogens from the National Institutes of Health or by the World Health Organization’s International Agency for Research on Cancer.
Why it matters: These substances pose substantial health risks because they are present in one of the most common exposure pathways for ordinary Americans: food. They are not just risky for consumers, but also for every worker involved in getting food to our plates. Let’s highlight a few examples of particular concern:
The law is clear: Cancer-causing chemicals are not allowed in our food. The 1958 Food Additives Amendment gives the FDA authority to regulate food chemicals. Within it, the Delaney Clause explicitly prohibits adding carcinogens to food. In contrast, the regulations FDA derives from the law allow carcinogens to be used if they are either absent from the final product or present only in trace amounts, making their inclusion a deliberate regulatory choice.
The FDA has maintained its approvals for chemicals long known to cause cancer, disregarding its responsibility to protect human health by enforcing regulations aligned with the law. Keeping carcinogens out of U.S. food is a clear mandate of the agency. While the law is straightforward, the FDA’s enforcement of it has been far from it.
Our take: The FDA’s decision to remove cancer-causing food additives should be quick and easy, particularly because safer substitutes are readily available. EDF and others have already petitioned the FDA to act on four cancer-causing substances, including methylene chloride, with no response for more than a year.
The FDA can take years to resolve cases that should be open-and-shut. In January 2025, the agency revoked an authorization for the color additive Red No.3, three years after EDF and partners submitted a petition citing decades of evidence of its carcinogenicity. The FDA’s response to comments on its January 2025 decision made clear that it was rooted in the Delaney Clause. But the slow response left this carcinogen in Americans’ food for three decades too long.
The FDA does not need to wait for groups like EDF to petition it to revoke approvals for carcinogens. The agency already has the legal authority — and responsibility — to keep carcinogenic substances out of U.S. food processing and food; it’s time they use it.
Read our analysis on the carcinogens found in food here.
Despite a 6-month delay and data gaps, EPA’s drastic reduction in lead service line counts may have unintended consequences.
What Happened?
After a 6-month long delay, EPA announced the next round of federal funding dedicated to lead service line replacement in late November. This year’s funding, totaling $3 billion, is allotted to states based on the service line inventories that were required to be submitted in October 2024.
This is the fourth year of the $15 billion funding as part of the Bipartisan Infrastructure law, dedicated to replace harmful lead pipes delivering drinking water to homes in thousands of communities.
Prior year allotments are based on EPA’s 7th Drinking Water Infrastructure Needs Survey and Assessment (DWINSA), a voluntary survey used to estimate water infrastructure needs. Now, the allotments are based on the service line inventories that utilities submitted to states as part of their requirements under the Lead and Copper Rule Revisions. This data is now driving the best current estimate of total lead pipes in the nation, which has drastically reduced from 9 million to 4 million.
How Did the Funding Change?
-Illinois received the greatest allotment – $309 million compared with $240 in FY24, a 29% increase.
-Michigan had the largest increase in allotted funds, receiving $87.5 million more than what they received in FY24.
-Florida had the largest decrease – from being allotted $228 million to just $34 million in FY25. (EDF has pointed out the issue with Florida receiving a large, outsized proportion of the money two years in a row and this issue has finally been resolved.)
-32 states are receiving the minimum allotted amount of $28.6 million – 8 of those were previously receiving more than that in FY24, with North Carolina losing the most ($47.6 million).
Check out the map below to see all the changes since the FY24 allotment.
What happened to all the lead service lines?
In EPA’s factsheet, the map shows a distribution of lead pipes around the country which seems to be more in line with previously thought assumptions – a high concentration of lead pipes in the Midwest and northeastern regions, with not many lead pipes at all in Florida and the west where there tend to be newer builds. Bizarrely, EPA’s estimated total number of lead service lines has more than halved, from $9 million to $4 million.
At first glance, the reduction in total lead pipes seems like a good thing – and in fact may reflect some progress in replacement across the country. However, it may be more likely that this dramatic reduction reflects an underestimate, which could prove to be challenging for utilities down the line.
EPA uses a formula to determine the allotments, pulling from data submitted by utilities on service line material types and projecting the number of each type in the state. They did make some questionable choices when it came to applying the data to address gaps in the service line inventories. For example:
-If a blank inventory was submitted, EPA assumed this meant the community is reporting all non-lead service lines. There is no indication that they validated this information with the community or the state directly. Almost 5,000 communities did not report anything.
-If a state did not report the number of non-lead service lines for a system but reported all other service material types, EPA estimated the number of non-lead service lines by taking the difference between their total service connections (from EPA’s SDWIS database) and reported number of service lines (from the October 2024 inventory). This could result in an inaccurate estimate by mislabeling lead service lines as non-lead. This applied to almost 6,000 communities.
While fewer lead pipes nationally would be a positive change, this drastic reduction may have unintended consequences if this new total is an underestimate, ultimately making it difficult for water utilities to plan effectively and receive needed funding for replacement.
Go Deeper
Read EPA’s memo on the funding allotments.
5 Takeaways from New York Climate Week
By Sarah Vogel, Senior Vice President, Healthy Communities, EDF, Dr. Arnab Ghosh, Assistant Professor of Medicine, Weill Cornell Medical College and Stefanie Le, Writer, Data Smart Cities
Extreme weather is no longer a distant threat—it’s here. NASA reports that in the past year alone, the U.S. saw twice as many extreme weather events as the 2003–2020 average. Storms are stronger, heat waves last longer and wildfires spread faster.
At New York Climate Week, leaders from cities, universities and health organizations gathered to ask a pressing question: how can data help communities protect themselves? The panel, hosted by Cornell Atkinson Center for Sustainability and Environmental Defense Fund with the Community Data Health Initiative, City of Detroit, NYC Department of Health, NYU’s City Health program and the African American Mayors Association, emphasized the role of data in shaping health-focused climate solutions.
Here are five takeaways:
Mount Vernon Mayor Shawyn Patterson-Howard described how data revealed a stark divide in her city: tree-lined streets in the north are up to 7 degrees cooler than the south side, where residents face higher asthma rates and utility bills.
“We don’t have the luxury of ignoring climate because we live at its intersection,” she said. “With a 5 to 7 degree difference in heat because urban heat islands on the south side, tree lined streets on the north side. And what does that cause? More asthma, more pulmonary issues and higher utility bills for the people that can afford them the least.”
Detroit is turning vacant land into opportunity. With more than 124,000 empty parcels, the city is converting lots into urban farms.
“It can’t be one or the other,” said Trisha Stein, Detroit’s Chief Strategy Officer. “We’re protecting the vulnerable, stabilizing neighborhoods, growing locally sourced food and generating $23 million in health benefits.”
Savannah Mayor Van Johnson put it bluntly:
“Seventy percent of our most intense storms have occurred since 2015. If we’re ever hit by a Category 3 hurricane, three-quarters of Savannah would be underwater.”
Margot Brown of EDF reminded the audience that climate change doesn’t create inequities—it deepens them.
“Climate change is what we call a threat multiplier. So it doesn’t just create new challenges, it worsens the ones that we already face, especially for the most vulnerable populations. People already facing poverty or racism are hit first and worst. That’s unfair—and avoidable.”
Representative Maxine Dexter (OR-03) recalled Oregon’s devastating 2020 wildfires, which burned more than a million acres. The smoke spread far beyond the fire line, endangering firefighters and residents alike.
“We must act with urgency and care,” she said. “The smoke literally goes where the wind blows it. Wildland firefighters have been out there with bandanas over their faces, fighting for generations. You don’t see mainland firefighters doing that anymore and we need that for our wildland firefighters.”
The message from New York Climate Week was clear: science and data must guide climate policy. As Representative Dexter put it,
“We should be depending on science to make policy. Citizens must demand investment in research and data collection.”
What’s new: Last month, the Environmental Protection Agency (EPA) withdrew a proposed rule covering 18 new chemicals, which would have paused industry efforts to turn toxic oils from plastic waste into fuel until the agency could review their health risks. Companies make these oils through pyrolysis, a controversial process that essentially burns plastic waste—often full of toxic additives like lead, phthalates and PFAS—at high temperatures. Industry has sought for years to re-brand this inefficient and dirty process as “advanced recycling”—a false solution to the plastic waste crisis.
Why it matters: In 2022, the EPA approved the production and use of the 18 chemicals despite significant health risks documented in the agency’s own analysis. These risks include an up-to 1-in-4 lifetime cancer risk—250,000 times greater than what the EPA typically considers acceptable. It was only after residents near the facility in Pascagoula, Mississippi that received the approval learned of these risks and filed a lawsuit that the EPA finally pulled it back.
As damning as the EPA’s 2022 analysis was, it almost certainly underestimated the true risks of the 18 chemicals by failing to consider the known health risks of toxic additives such as lead, PFAS and dioxins commonly found in waste-plastic pyrolysis oils. In response to mounting pressure, the EPA issued the proposed rule in 2023 to address these additional risks. Because it is nearly impossible to make fuels from these oils that are free from toxicants, the rule had an immediate chilling effect on industry investment in “advanced recycling” that’s thawing now that it has been withdrawn.
Our Take: The proposed rule was effective because it would have required companies to notify the EPA before producing and using the new chemicals when they contain toxic plastic additives by designating it as a significant new use. This designation also would have given the agency time to evaluate potential risks to human health and the environment—and mitigate them if necessary.
The proposed rule was also significant because it represents the first time the EPA officially acknowledged that waste plastic-derived pyrolysis oils contain toxic additives “known to cause cancer and harm the reproductive system, among other health effects.” While we believe this rule (and the list of toxic chemicals requiring review) did not go far enough—and submitted comments to the EPA in 2023 explaining why—it was a big step in the right direction.
What’s the problem with so-called “advanced recycling?” Although industry touts “advanced recycling” as a solution to the plastic waste crisis, the process has major flaws. Not only does it fail to recycle anything, but it also rarely results in new plastic products. To make matters worse, the oils it produces are so toxic that their use is highly limited. Continued investments in “advanced recycling” will lock us into burning more polluting fossil fuels that contribute to climate change. Instead of spending its resources propping up this toxic scam, industry could devote them to developing truly innovative and safe solutions.
What’s next? With the rule now out of the way, the EPA is likely to reissue its approval of the 18 chemicals and propose a new set of “rules” that would ignore both the known cancer risks and the additional risks from the highly toxic additives. This would be an unacceptable outcome for public health. The agency must consider the full picture of risk—not just part of it.
With industry actively pushing to develop new facilities across the country—and simultaneously seeking exemptions from other pollution limits for facilities like the one in Pascagoula—the EPA’s reversal opens the door to more pollution and greater harm to both people and the environment. We must hold both the EPA and industry accountable to ensure these plastic waste-derived new chemicals filled with dangerous toxins are not approved—and that any future rules protect people and the environment from unreasonable risk.
To learn more about the health risks of “advanced recycling,” check out this recent Instagram reel by Sarah Vogel, Senior Vice President of Healthy Communities.
What’s new: A new report has found the cancer-linked endocrine disruptor, nonylphenol (NP), in one-third of tested Indian clothing products at levels exceeding European Union (EU) safety standards.
Scientists also detected NP in major Indian rivers downstream from textile hubs at levels that significantly exceeded international water quality standards. The report, Toxic Threads, was published by the Indian environmental research and advocacy organization Toxics Link in partnership with Environmental Defense Fund.
What is NP and where does it come from? NP is a chemical byproduct of degrading nonylphenol ethoxylates (NPEs), which manufacturers across several sectors use as a base ingredient in detergents, wetting agents, dispersants, defoamers, de-inkers and antistatic agents. Textile producers use NPEs most commonly in cleaning agents.
The Toxic Threads report’s key findings include:
Why it matters: NP is an endocrine disruptor and has been linked to cancer. People, particularly children, can be exposed to it through everyday products they touch or might put in their mouths. NP’s persistence (how long it lasts), toxicity and ability to build up in the body over time makes it a significant threat to human health, the environment, marine ecosystems and the food chain. Because many textiles produced in India are exported, the associated health risks could extend to consumers in importing countries that don’t regulate NP in clothing, such as the United States.
How can India protect its people and aquatic life from the dangers of NP? While several countries have taken proactive measures, India has yet to fully regulate against the harms of NP and NPE contamination.
The report recommends Indian leaders take decisive action to align with global efforts in restricting NP and NPE use. Strengthening regulations and promoting safer alternatives in textile manufacturing and consumer products are key to safeguarding human and environmental health and ensuring sustainable market practices.
Go deeper: Read the full Toxic Threads report here.
What Happened:
Bipartisan support is growing for food safety reform as U.S. Food and Drug Administration (FDA) is considering comments on a new process for reassessing chemicals already on the market . On January 21, EDF submitted comments to FDA on how the agency should strengthen its proposal for a process to ensure the safety of existing ingredients in the market. While EDF supports modernizing FDA’s Human Food Program processes and methods, the current proposal falls short on transparency, efficiency, and scientific rigor.
Why it Matters:
The public deserves a systematic, science-based approach to food chemical safety. FDA’s current process is outdated, opaque, and reactive rather than proactive. Delays in addressing chemical safety are common, with FDA often taking years to act on food additive petitions and chemical reassessments. Many food chemicals were approved decades ago using little or no data and have not been reevaluated since.
FDA often relies only on its own studies, while ignoring or disregarding findings from other authoritative institutions such as the National Institutes of Health (NIH) and the European Food Safety Authority (EFSA), seemingly unable to acknowledge modernizing science. This failure to consider the full picture and the best available science undermines public health.
Additionally, the agency fails to consider the cumulative effects of multiple related substances. People aren’t exposed to single chemicals in isolation, yet the FDA continues to evaluate them as if they are.
While FDA leadership has emphasized that food chemical safety is a top priority for the Human Foods Program, historical lack of action has driven states like California to implement its own food additive regulations. This state-by-state approach creates a patchwork of rules that highlights the urgency for stronger federal leadership to protect all Americans from toxic chemicals.
Our Take:
FDA’s proposed process is a step forward but needs significant improvements.
While developing this process, FDA can take immediate action on priority chemicals. EDF and others have already petitioned the agency to act on harmful phthalates, per- and poly-fluoroalkyl substances (PFAS), cancer-causing solvents (including methylene chloride), and titanium dioxide, BPA and lead. These toxic chemicals do not belong in our food. With growing bipartisan support for stronger food safety regulations, FDA has an obligation to be a leader in this space. About two-thirds of American adults across political ideologies “strongly or somewhat favor” restricting or reformulating processed foods to remove added sugars and dyes signifying wide support for greater regulation on food additives.
Next Steps:
It is critical that FDA reevaluates its processes for determining the safety of chemicals in our food. EDF will continue to pressure FDA to act now on high-priority food chemicals, using the best available science and enforcing laws that effectively protect people’s health.
Go Deeper:
Read the full version of the comments EDF submitted to FDA here.
