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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ICYMI: Secret GRAS determinations may outnumber those FDA reviews

Quote from FDA Commissioner Robert Califf, MD. "I want to throw in chemical safety as another really, really important area for the future—for humankind, really—and where science is evolving rapidly."

NOTE: This blog was originally published on our Deep Dives blog on April 13, 2023. It predates the recent reorganization efforts at FDA.

What Happened?

FDA estimates that, each year, food companies designate 82 new food chemicals as “GRAS” (Generally Recognized as Safe) for use in food. On average, FDA reviews only 64 of those new chemicals for safety. For the remaining 18 chemicals in FDA’s estimate, the companies making and marketing them for use in food or in the food-production process choose not to seek a voluntary review by FDA.

In comments to the agency, we said we think FDA’s estimate may be too low – and the number of new chemicals added to food that bypass FDA review may be as high as 130 new food chemicals a year (significantly higher than 18). This is based on searches of company marketing claims. In an 8-week period, we identified 10 chemicals claimed as GRAS without a submitted notice to FDA seeking voluntary review. (Please see our comments for a full explanation of our estimate.)

Why It Matters

FDA’s review of GRAS safety determinations is critical to ensure food chemicals are safe. When agency scientists receive GRAS notices, they closely review them and ask notifiers tough questions about the safety of the chemical alone—and the potential consequences when that chemical is combined with other chemicals on the market.

But FDA allows companies to withdraw their notices – which they do in about 17% of cases. Sometimes companies fix the problems and resubmit the notice. FDA does not require companies to do this, however. Too many simply continue to market the chemical for food uses as GRAS without seeking further FDA review.

This is in addition to the GRAS safety determinations companies choose never to file, which leads to chemicals entering our food system without any FDA notice or review at all.

Our Take

While the GRAS system is clearly broken (something we’ve blogged about at length and the Washington Post covered in-depth back in 2014), FDA does retain the ability and the duty to monitor the marketplace to ensure unsafe chemicals that food companies claim as GRAS are kept off the market.

Unfortunately, the agency appears to lack any system to ensure that monitoring takes place. The only examples of agency action to pull industry-certified GRAS products off the market have been caffeinated alcoholic beverages and partially hydrogenated oils (aka artificial trans fat). Both were prompted, in part, by state and media calls for action.

Examples of inaction, however, are numerous and include: tara flour, COZ corn oil, Apocynun ventron, gamma aminobutyric acid (GABA), aquaequorin/Prevagen, and many more.

One of the key breakdowns that contributes to FDA’s failure to monitor is the lack of coordination between the regulatory programs in the Center for Food Safety and Applied Nutrition (CFSAN) and the inspection/enforcement programs in the Office of Regulatory Affairs (ORA).

Next Steps

In January 2023, FDA Commissioner Califf announced a proposal to reorganize the food safety program in response to stakeholder calls for action after the infant formula debacle and to a recent review of the agency by the Reagan-Udall Foundation. This review noted that one key step is to appoint a new Deputy Commissioner for Human Food. This person would have greater responsibility to coordinate efforts between CFSAN and ORA. The Commissioner’s proposal has been strongly criticized since there would be no clear line of authority between the new Deputy Commissioner and ORA.

But Commissioner Califf has stated that chemical safety is a priority, telling a reporter that “I want to throw in chemical safety as another really, really important area for the future – for humankind, really – and where science is evolving rapidly.”1

Fixing GRAS is an important step to rebuild consumer confidence and reduce the ongoing risk to public health. Until the broken GRAS system is fixed, FDA will continue to be hamstrung in preventing health risks posed by chemicals of unknown safety. Until the system is fully fixed—which includes ensuring that no chemicals enter our food system without notice to, and review by, the agency—FDA needs to be coordinating with ORA and CFSAN to proactively monitor and enforce GRAS evaluations on chemicals entering the market to ensure they are actually safe.

Go Deeper

You can learn more from these resources:



1 FoodFix, January 31, 2023, edition.

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Unleaded Food: FDA acts quickly on contaminated cinnamon applesauce

What’s Happening?

The North Carolina Departments of Health & Human Services and Agriculture & Consumer Services identified WanaBana cinnamon applesauce pouches as a source for elevated blood lead levels in multiple children. They found extraordinarily high concentrations of lead (1,900- 5,100 ppb) in the products, leading to the identification of at least 34 cases of elevated blood lead levels across 22 states to date.

On October 28, 2023, FDA issued a safety alert advising that “parents and caregivers of toddlers and young children who may have consumed WanaBana apple cinnamon fruit puree pouches should contact their child’s healthcare provider about getting a blood test.” Three days later, the company issued a voluntary recall.

As the recall expanded, FDA transferred the investigation to its Coordinated Outbreak Response & Evaluation (CORE) Network to determine the source of lead contamination and whether additional products are linked to illnesses.

Brands under a voluntary recall. Photo credit: FDA

Brands under a voluntary recall. Photo credit: FDA

Why It Matters

Lead levels in the puree ranged from 1,900 to 5,100 parts per billion (ppb). A single serving with 2,000 ppb exposed children to a lead level 64 times greater than FDA’s maximum daily intake of 2.2 micrograms/day (µg/day) for a child and 11 times greater than the 12.5 (µg/day) for an adult.

We will continue to note that there is no safe level of exposure to lead—making it toxic at any age, with heightened concern for children aged six and below. In homes without lead pipes or lead paint, diet is the primary source of lead exposure for young children. Read More »

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California mandates toxics testing/disclosure for baby food

Tom Neltner, Senior Director, Safer Chemicals and Katelyn Roedner Sutter, State Director, California

Three jars of baby food surrounded by cut-up vegetables and fruit

What Happened?

On October 10, 2023, California Assembly Bill 899, authored by Assembly Member Al Muratsuchi, became law. It requires manufacturers of baby food (other than infant formula) who wish to sell their products in California to:

  • Test a representative sample of each baby food product for four toxic elements (arsenic, cadmium, lead, and mercury) at least monthly starting in 2024.
  • Provide the test results to the California Department of Health upon request.
  • Make the results of the testing publicly available on the manufacturer’s website for the shelf life of the product plus one month. That provision goes into effect in 2025.

In addition, as FDA establishes action levels for the four toxic elements, manufacturers must also include a quick response (QR) code on the label that links to the manufacturer’s website, where consumers can find the test results for that toxic element.

Why It Matters

By requiring testing and reporting on these foods, California will provide parents and guardians with important information they need to compare products and make purchasing decisions. The law also:

  • Sets a precedent for greater testing and disclosure of food contaminants; and,
  • Is noteworthy, in that baby food companies did not oppose the bill.

The law will strengthen FDA’s efforts to reduce children’s dietary exposure to those toxic elements to the lowest possible levels, while maintaining access to nutritious foods by filling two critical gaps in FDA’s Closer to Zero program. FDA current approach sets action levels on final products that food companies must meet and requires they use preventive controls to manage toxic elements in their ingredients. It does not require final product testing or disclosure of any testing results.

Read More »

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Broken GRAS: Companies ignore FDA draft guidance; Bias & conflicts of interest prevail in safety determinations

By Tom Neltner, Senior Director, Safer Chemicals, Klara Matouskova, PhD, Consultant, and Maricel Maffini, PhD, Consultant

What Happened?

In our new study, we evaluated Generally Recognized As Safe (GRAS) notices—a total of 403 between 2015-2020that food manufacturers voluntarily submitted to FDA for review. Our goal was to determine whether industry was adhering to FDA’s Guidance on Best Practices for Convening a GRAS Panel.

The guidance was designed to help companies comply with the law and avoid biases and conflicts of interest when determining whether substances added to food are safe and recognized as such by the scientific community. FDA published a draft of the guidance in 2017 and finalized it essentially unchanged in December 2022.Infographic showing how a small group of individuals populate almost half of GRAS review panels. Seven individuals accounted for 46 percent of available panel positions.

Our study found that no GRAS notices followed the draft guidance. Specifically, we also found there were high risks of bias and conflicts of interest because the companies:

  • Had a role—either directly or through a hired third party—in
    selecting panelists that likely resulted in bias and conflicts of interest.
  • Depended on a small pool of experts in which seven individuals occupied 46% of panel positions. The seven often served together, further enhancing risk of bias.
  • Relied on panels that did not realistically reflect the diverse scientific community that evaluates chemical risks to public health—which is needed to comply with the law’s requirement that there be a “general recognition” within that community that a substance is GRAS.

Read More »

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Broken GRAS: FDA’s lack of post-market oversight continues to create health risks

Brown glass vial surrounded by pepper corns

What Happened?

In April, a company called Prime Research Reports issued a press release in which it claimed FDA had approved THP (tetrahydropiperine) as a Generally Recognized As Safe (GRAS) substance “for use in food products.” There is no record that FDA has either reviewed or approved THP for use in food.

The report describes Sabinsa as a manufacturer of THP and as “a major player” in that market.[1] The substance, commercially known as Cosmoperine, is derived from a highly purified extract from black pepper; the extract, which is more than 95% piperine, is also made by Sabinsa and is marketed as BioPerine. The company describes piperine as an alkaloid present in black and long pepper.

Read More »

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