Perfluoroalky and polyfluoroalkyl substances (PFAS) can be used to make cardboard and paper food contact materials oil- and water-repellent. It is difficult to break down perfluoroalky and polyfluoroalkyl substances in the environment; some of them are retained in animals and people, and several of them are suspected of being carcinogenic, disruptive to hormones and damaging to the immune system. There are now alternatives to perfluoroalky and polyfluoroalkyl substances. For example, mechanical treatment of paper can make it stronger and more repellent, or a different surface layer can be added to the paper. In December 2018, EFSA published an enhanced risk assessment for two of the substances (PFOS and PFOA), in which the amount that we can absorb before harmful effects may arise was drastically reduced. Denmark’s Technical University (DTU), the National Food Institute agrees with EFSA’s enhanced risk assessment for the two fluorinated substances, and the Institute has previously (in 2017) made the assessment that it is also unlikely that data will be found in the coming decades that will make it possible to undertake detailed risk assessments for all perfluoroalky and polyfluoroalkyl substances. DTU also observes that on the basis of the knowledge that the Technical University currently has on the substances, there is a good basis for reducing the exposure of the population not just to PFOA but also to other compounds similar to fluorinated substances, since DTU expects that the other perfluoroalky and polyfluoroalkyl substances will display similar effects in people and animals. The Institute has also shown in experiments that fluorinated substances in cardboard and paper packaging can migrate into food. DTU expressed its concern about perfluorinated alkylcarboxylic acids (PFCAs) and alkylsulfonic acids (PFSAs) in October 2019. They conclude that perfluorinated alkylcarboxylic acids (PFCAs) with chain lengths from C4 up to at least C11 are able to activate the PPARα receptor, which is a molecular mechanism that can among other things lead to damage to the reproductive system. Perfluorinated alkylsulfonic acids (PFSAs) with a chain length of C6 and C8 can affect the immune defence system and cause lung damage. DTU also states that PFCA and PFSA are expected to cause cocktail effects and that account should therefore be taken of exposure to all PFCAs and PFSAs in future risk assessments. It is not news that perfluoroalky and polyfluoroalkyl substances can have damaging characteristics. Before this proposal for a ban, Denmark has tried to use less invasive measures to reduce the exposure of the population to perfluoroalky and polyfluoroalkyl substances, including guidance to consumers and business, determination of an indicator value for unavoidable background level of total organic fluorine in paper and voluntary phasing out of the substances. But there are still food contact materials made of cardboard and paper on the Danish market with a content of perfluoroalky and polyfluoroalkyl substances, which suggests that perfluoroalky and polyfluoroalkyl substances have been used. These measures have therefore proved inadequate, for which reason the current ban is considered to be the only realistic measure that Denmark can take to protect Danish consumers against the migration of perfluoroalky and polyfluoroalkyl substances into food from food contact materials made of cardboard and paper. The Danish ban is targeted to reduce the risk of Danish consumers’ exposure to perfluoroalky and polyfluoroalkyl substances from food contact materials made of cardboard and paper, by preventing the possibility of migration.

The purpose of the Order is to ban the placement on the market of food contact material made of cardboard and paper if perfluoroalky and polyfluoroalkyl substances (PFAS) have been used.