EDF Health

New Updates to Understanding Packaging Scorecard Spur a Safer & More Sustainable Foodservice Industry

Amid growing concerns about the environmental impact of single-use plastics, consumers have increasingly sought out alternatives made with renewable materials—as demonstrated by the rise in popularity of the paper straw. Unfortunately, this summer many eco-conscious consumers were devastated to learn of a recent analysis of drinking straws that detected PFAS in paper straws.1

These toxic chemicals, often referred to as “forever chemicals” for their persistence in the human body and the environment, have been linked to serious health concerns and environmental contamination leading to additional exposures beyond the original PFAS-containing article.

The plant-based straw controversy serves as a poignant reminder that even seemingly sustainable and eco-friendly alternatives can harbor hidden health and environmental risks. It also underscores the urgency of tools like the Understanding Packaging (UP) Scorecard in helping foodservice companies navigate the complex landscape of sustainable food packaging to make choices that both protect human health as well as the environment.

Consumers are both wary of toxic chemicals in their food and more environmentally aware than ever. In a 2022 survey (PDF, 2.6MB) of U.S. consumers, it was found that “cancer-causing chemicals in food” are still the second most important food safety issue to Americans, right after foodborne illnesses. Further, 82% of consumers across age demographics are willing to pay more for sustainable packaging, according to a 2023 survey of 9,000 consumers spanning Europe, North America and South America. With the ever-growing demand for sustainable packaging, companies need tools to help advance their planet-forward goals.

The UP Scorecard is a science-based online tool designed to assist foodservice companies in choosing foodware and food packaging that not only meets demands for safety but also aligns with their sustainability goals. One of the world’s leading foodservice companies, Compass Group, uses the UP Scorecard to help prioritize sustainability goals and drive down plastics and PFAS in their product offerings, as demonstrated in their case study.

The latest version of this sustainability tool, released [November 28, 2023], takes a significant leap forward: by improving its scoring system for toxic chemicals, the UP Scorecard offers a more comprehensive view of the health impacts of different packaging materials and how to choose healthier options for customers and the environment.

A Deeper Dive into the Updates

1. Enhanced Scoring System: The updated scoring system considers various factors, including food temperature, fat content, acidity, and more, when assessing the potential human health impacts of a certain packaging material. For instance, certain toxic chemicals may migrate into food at higher temperatures or have a higher affinity for fats. The UP Scorecard accounts for this, providing a lower score for packaging containing such chemicals when used to hold hot or high-fat foods. This nuanced approach ensures that procurement professionals can make more precise decisions based on specific use cases and product requirements.

2. User-Friendly Portfolios: One of the most significant improvements in this version is the ability for users to save and score portfolios representing entire business units. Now, foodservice companies can easily assess the sustainability and safety of their entire product lineup, making the decision-making process faster and more efficient for their procurement teams. And it makes it easier to see big-picture progress and advance toward longer term goals.

3. User Accounts: The addition of user accounts allows professionals to manage their tool preferences, save customized products and portfolios for future reference, and even collaborate by sharing their projects with others. This feature promotes teamwork and knowledge sharing within organizations.

4. Benchmarking Capabilities: The updated UP Scorecard introduces a benchmarking system that enables users to compare different portfolios. This function is invaluable for companies looking to continuously improve their sustainability efforts.

By leveraging the UP Scorecard, foodservice companies can make well-informed decisions that not only benefit their bottom line and meet consumer demand and expectations for safe food packaging, but also contribute to a safer and more sustainable food industry.

About the UP Scorecard

The UP Scorecard measures commonly used foodware and food packaging materials with a single yardstick to offer the first-ever, free, and comprehensive tool for making sustainable purchasing decisions for these products based on the latest available science. Scores are provided for plastic pollution, chemicals of concern, climate, water use, sustainable sourcing, and recoverability. Developed through an unprecedented collaboration of leading food service companies, NGOs and technical experts, the UP Scorecard provides an authoritative resource for businesses as well as for environmental and human health advocates.

Environmental Defense Fund is a proud partner on this collaborative effort to help foodservice companies both achieve climate goals while also protecting consumer safety. With the latest enhancements, it’s easier than ever to select food packaging that aligns with the highest standards of safety and sustainability.


1 The study detected PFAS in paper, plastic, bamboo, and glass straws.

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European Commission plans to ban food uses of BPA. We ask again: Where is FDA?

Maricel Maffini, consultant, and Tom Neltner, Senior Director, Safer Chemicals

What Happened?

On June 2, the European Commission, the executive body of the European Union (EU) responsible for proposing legislation and implementing decisions, announced it is preparing an initiative that “will impose a ban on the use of BPA [bisphenol A] in food contact materials (FCMs), including plastic and coated packaging.” It also said it would “address the use of other bisphenols in FCMs to avoid replacing BPA with other harmful substances.” The Commission’s proposal is based on the European Food Safety Authority’s (EFSA) scientific opinion that exposure to BPA is a “concern for human health.”

Why It Matters

In April, EFSA concluded that Europeans were exposed to levels of BPA from food that were 100 to 1,000 times greater than the estimated safe amount, and that this exposure could lead to an overactive immune system producing out-of-control inflammation. BPA was also associated with disrupting the endocrine system, harming reproduction, and reducing learning and memory. The immune system was most sensitive to BPA exposure. Recognizing these risks, the Commission moved quickly to protect Europeans’ public health by banning uses of BPA.

Our Take

Americans’ exposure to BPA from food is similar to that in Europe. Unfortunately, FDA doesn’t share the same sense of urgency to protect our families as the European Commission is demonstrating by its actions. While Europe is moving forward to ban the use of BPA in food contact materials, the FDA has failed to take action.

EDF and our allies submitted a food additive petition asking the agency to limit BPA exposure from food by revoking approvals for using BPA in adhesives and can coatings and to setting strict limits on using BPA in plastic that contacts food. FDA filed the petition on May 2, 2022 and has not made a final decision on it despite a 180-day statutory deadline. It is now more than 400 days overdue.

In January, FDA Commissioner Califf announced “a new and transformative vision for the FDA Human Food Programs” which includes a Deputy Commissioner for Human Foods with “decision-making authority over policy, strategy and regulatory program activities.” These are important steps, but a real measure is making timely decisions to protect American’s health by restricting the use of toxic chemicals such as BPA.

Pile of silver metal food cans with no labels

Next Steps

We will continue to press FDA to make a final decision on the petition, including potentially taking legal action for unreasonable delay in responding to our petition.

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FDA acts on fluorinated plastic packaging. What are next steps?

Tom Neltner, Chemicals Policy Director and Maricel Maffini, consultant

The Food and Drug Administration (FDA) took an important step last week to protect food from PFAS contamination from plastic packaging. On August 5, the agency sent a letter to manufacturers, distributors, and users of fluorinated polyethylene food contact articles reminding them that these articles must be made under specific conditions to comply with existing regulation or otherwise the food contact articles “are not lawful.” Therefore, the food that contacted them should not be permitted for sale. The agency gave three examples of manufacturing processes that do not comply with the regulation. We flagged concerns with fluorinated plastic packaging in a July blog and applaud the agency for this action.

This significant first step needs to be followed:

  1. Investigate the companies that provided fluorinated plastic packaging for food and cosmetic uses to determine whether their products complied with the law. If not, then alert food manufacturers and retailers so they can recall the adulterated food and cosmetics.
  2. Reassess whether the process FDA approved in 1983 for fluorinating polyethylene generates PFAS and whether it should still be considered safe.

Investigate companies that provided fluorinated plastic packaging

In the letter, FDA’s Office of Food Additive Safety (OFAS) states that “available information indicates that some manufacturers of fluorinated polyethylene produce articles via alternative manufacturing methods from that stipulated in FDA’s regulation.” It identified three specific examples and says that “these alternative processes for fluorination of polyethylene are not compliant with 21 CFR § 177.1615, and are not lawful for use in food contact articles.” The three examples of unlawful manufacturing processes are:

  1. “Fluorination of polyethylene for non-food uses may occur during the fabrication or molding of the container.”
  2. “Use of fluorine gas in combination with other inert diluents such as carbon dioxide, helium, or argon.”
  3. Incorporation of oxygen into the fluorinating mixture to modify the properties of the final container.

A market search shows several brands that have in-mold fluorination of high-density polyethylene (HDPE), (here and here) and another that may use oxygen or other gases in combination with fluorine.

With the letter public, FDA’s Office of Regulatory Affairs (ORA), which handles field inspections and sampling for the agency, should ensure compliance by food manufacturers all along the supply chain. Where it finds a violation, it would manage the recall of the adulterated food.

Reassess whether the allowed use generates PFAS and should still be considered safe

About a week before FDA sent out the letter, the agency responded to our May 2021 FOIA request for the documentation that resulted in its 1983 approval of fluorinated polyethylene packaging at 21 CFR § 177.1615. The approval came in response to a 1979 food additive petition by Union Carbide.

As with most of FDA’s FOIA responses, the 233-page document has extensive redactions of health and safety information. However, two things come through clearly:

  1. Nitrogen and fluorine only: In its petition and communications with FDA, Union Carbide was inconsistent when it explained whether nitrogen was only an example of an acceptable inert gas. FDA scientists demanded clarity and the company agreed that only nitrogen would be allowed. In its recent letter, FDA reminds companies that only this condition is approved.
  2. Fluorinated organics: The petition included studies of the chemicals that migrated into a simulated food such as water or alcohol. The study evaluated the residue that remained after the food simulant was evaporated off. Union Carbide maintained that fluorine in the residue was almost entirely ionic fluorine – the kind added to toothpaste – and showed that the exposure was within tolerated levels. FDA scientists kept pushing back explaining that there was evidence the residue contained substances with a carbon-fluorine bond – a indicator of what we now refer to as PFAS. FDA finally relented, stating that “our general conclusion is that low molecular weight fluorocarbon-oxygen compounds should not be present in significant quantities.” (see page 195 of FOIA response).

We now know that levels of PFAS that were considered insignificant by FDA in the 1980s pose significant risks as evidenced by some of the agency’s recent actions. For those reasons, we reaffirm our call in our July 2021 blog and in the June 2021 citizens petition submitted by 11 organizations to FDA to reassess the safety of PFAS uses, including fluorinated polyethylene.

As part of that reassessment, FDA needs to revisit the concerns raised by the agency scientists in 1983 in light of the risks posed by PFAS. Specifically:

  • Nitrogen: In its August 5 letter, FDA states that a form of PFAS known as perfluoroalkyl carboxylic acids “can form when the fluorination of HDPE occurs in the presence of oxygen or water, but not in the presence of nitrogen.” However, the agency does not acknowledge that commercially available nitrogen contains contaminants like oxygen. Food-grade nitrogen can have as much as 10,000 parts per million (ppm) of oxygen and 55 ppm of water. These levels could well be sufficient to generate significant amounts of PFAS.
  • PFAS leaching into food: Since the amount of PFAS in food considered “significant” is dramatically lower than in 1983 when FDA made its decision, the agency needs to evaluate whether it is practical – even with the purest nitrogen – to fluorinate plastic without making PFAS.

If the agency determines that the fluorine gas treatment process creates any PFAS, the law explicitly requires that FDA evaluate safety after taking into account the cumulative effects of related substances in the diet that have related health impacts. As with virtually all of its decisions, the agency failed to do that for its 1983 approval. Given the pervasive presence of PFAS in the environment and the additional PFAS FDA authorized for use in food packaging, this type of review is even more important.


In summary, FDA’s August 5, 2021 letter is an important step in the effort to protect consumers from PFAS in food. Now the agency needs to investigate the companies that provided fluorinated plastic packaging for food and cosmetic uses to determine whether the products complied with the law and take action. It must also reassess the safety of the packaging even if it complies with the specific conditions in its 1983 approval.

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