Lots of people are aware that compostable packaging is not a perfect solution to our takeaway waste woes, but what if this is partly to do with the fact it could contain toxic or harmful elements? And, what if we told you that when we’re talking about toxicity, we shouldn’t only be pointing the finger at plastics? The world of emerging compostable materials and products presents a complex range of concerns, overlaps and puzzles, which are extremely difficult to unravel. The lack of transparency about what packaging is actually made of, combined with regulations that lag behind packaging innovation, is failing to empower everyday humans to work out what’s safe and what isn’t, and risking harm to human and environmental health.

There’s a growing awareness that while compostable serviceware sounds superficially great in theory, the practical reality is fraught with difficulty.

It’s very apparent that we lack nationwide collection systems and infrastructure to ensure compostables actually gets composted, and that most commercial composters aren’t keen on accepting compostable packaging. As consumers, we now notice that a great deal of compostable packaging goes into landfill (along with its non-compostable cousins), and that this is far from ideal. Within the anaerobic landfill conditions, these products create the dangerous greenhouse gas, methane.

Increasingly, people also understand that all single-use packaging is inherently unsustainable - wasting energy and resources, and fuelling climate change and resource depletion - regardless of what it’s made of.[1]

But, what about the quiet assumption that, for all its logistical flaws, at least compostable packaging is a non-toxic alternative to conventional disposable products - harmless to use, safe for our bodies, and beneficial for the soil when composted? After all, it’s made from plants, and sports pictures of leaves, green fonts, and happy words like “eco”, right?

It seems this assumption is based more on faith than fact. Contrary to popular belief and the wholesome marketing, there’s a chance that some compostable serviceware could contain harmful additives or sneaky microplastics. The upshot? Compostables are not necessarily safe for you and the planet – EVEN the stuff that’s certified compostable.

In fact, compostable packaging could be transmitting harmful chemicals or microplastics into

the food you’re about to eat that is held by the packaging
the soil and groundwater, if that packaging is composted
the food chain (both plants and animals) and drinking water.

Are we being overly dramatic here?

No, but the issue is not simple, nor black and white.

This two-part post is about sharing some of the emerging evidence surrounding problematic additives in packaging, and what this could mean for human and environmental health. In Part 1 (this post!) we’re doing a deep dive into fibre-based compostable serviceware (whether or not it’s ‘plastic-free’). Fibre = things like paper, cardboard, bagasse, etc. Compostable plastics require a separate analysis and we’ll do that in Part 2.

First things first...

1. We’re not saying ALL compostable packaging is toxic...

… we’re saying there’s a chance some compostable packaging contains certain additives known to be persistent organic pollutants, carcinogens, endocrine/hormonal or immune disruptors, or microplastic polymers. Regulations and composting certification systems haven’t kept up with the range of potential additives or innovations out there, and packaging companies aren’t required to disclose what’s in their packaging (and nor do they want to because it’s commercially sensitive proprietary information).[2]

This puts us in the dark. One key idea in environmental policy is the precautionary principle, which says that if there’s a risk of something less than safe, and we operate in a space of uncertainty, we should err on the side of caution, not the side of ‘she’ll be right’.

2. Ecotoxicity and threats to public health - just because we can’t see it, doesn’t mean it’s not there

The story of compostable packaging relies on the belief that it’s OK to use the soil as a waste disposal system for synthetic products. But, if we’re going to do this, we hold a duty of care to ensure we’re only putting stuff that’s safe into the soil and the natural environment.

This is often not front of mind for the public, regulators or even those bodies that undertake official compostability certifications. The emphasis, when assessing if compostable packaging is ‘legit’, has fallen more heavily on the physical breakdown of the packaging, rather than questioning whether any concerning residual chemicals are left behind.[3]

Just because we can’t see a compostable product anymore, doesn’t necessarily mean it’s not left nasties behind in our compost.

In other words, measuring success for compostability is overly focused on whether the compostable disappears from sight. Very often we hear people say - 'this compostable packaging totally works! I put it in my compost and it’s completely gone!' Hardly ever do we hear, 'I wonder what it has broken down into, and is this safe for us or the soil?'.

And yet, there are many things out there that aren’t visible to the human eye, that can harm us and the natural environment. Just because we can't see a compostable product anymore, doesn't necessarily mean it's not left nasties behind in our compost. Ignoring this and simply celebrating the successful vanishing of a compostable package doesn’t sound that different from the outdated idea that burning plastic ‘makes it go away’.

To be clear, compostability certifications do include a preliminary ingredient check to ensure things like heavy metals are not present in compostables, and they do follow up with ecotoxicity tests on soil after the compostable product’s breakdown. The problem is that you only find what you test for - no certification tests for the wide range of potential additives or even polymers that may be added to products these days.[4]

You may think that questionable things wouldn’t be added to compostable packaging, but there are good reasons to suspect they probably are. First, most official certifications allow compostable packaging to contain a small percentage of non-compostable ingredients. Second, it’s already well-known that thousands of synthetic chemicals are currently added (legally) to food contact materials (FCM) globally, and that these can transfer from FCM into food. Some of these are known to be safe, some are known to be unsafe, some are being used even though we don’t yet know if they’re safe or not.[5] If these additives are already permitted in traditional FCMs, they’re very likely used in compostable packaging too.

This risk is recognised by a growing number of scientists with expertise in areas such as toxicology, environmental science and public health. These experts are noting society’s drive towards sustainable packaging solutions that support a circular economy, and are calling for these solutions to be informed by scientific evidence about human and environmental safety.[6] The last thing we should be doing is marching off and inventing compostable packaging to put in food-growing soils, without a robust safety assessment system to protect us from ourselves. As Ritson and Peake note:[7]

The rise in compostable material used to replace single-use plastic opens new avenues for the potential for chemicals to re-enter the food chain and be released into the wider environment when compost is spread on soils. As the economy becomes more circular, the use of potentially harmful chemicals must be addressed.

3. This post is focused on fibre-based compostable serviceware

Different types of compostable packaging are used for takeaway food and drink, and lots of them contain fibre (paper, cardboard, bagasse etc). The below is not an official categorisation, but is helpful for the purposes of this post.

1) Plastic-free compostable packaging made of fibres, such as paper/cardboard, sugarcane or bagasse plates or clamshells, plastic-free coffee cups, bamboo cutlery etc. This stuff is usually marketed and/or certified as both home compostable and commercially compostable. Without the addition of tricky compostable plastics. like PLA, this compostable packaging breaks down easily and the fibre adds carbon to composts. More and more events and takeaway outlets are choosing this type of compostable packaging for their food to-go. Roughly half of the compostable packaging on the market (by unit and by weight) in NZ is this category.

2) Compostable plastic packaging, e.g. PLA, which includes packaging that is purely compostable plastic (like those compostable smoothie cups and coffee cup lids) and composite products (like cardboard/paper coffee cups or containers with an inner compostable plastic lining). Usually, serviceware containing plant-based compostable plastic like PLA requires commercial composting. However, many of New Zealand’s commercial composts will not accept PLA because it’s difficult to break down and undermines the value of the final compost. The composite products with a fibre element will be touched on in this post.

3) Paper and cardboard takeaway packaging that isn’t necessarily marketed as compostable (and generally not certified as such), but which many people compost or recycle instead of binning, such as pizza boxes and brown paper bags.

In this post, we’re focusing on plastic-free compostable serviceware or any other takeaway packaging with a fibre (paper, cardboard, bagasse etc.) element. Compostable plastic is another story for another day (watch this space…!).

The Takeaway Point: ‘plastic-free’ or other fibre-based compostable serviceware may contain unhealthy additives that have been intentionally or non-intentionally added to the product.

Serviceware usually needs to be resistant to liquid and grease

The thing about plastic (whether fossil or plant-based) is that it’s pretty resistant to/repellent of moisture and grease. This is quite handy when you are making a cup or container to hold food and drinks, and don’t want it to leak and fall apart in people’s hands.

Water and grease resistance is not a characteristic of paper, cardboard and most other fibres. Think about it - when was the last time you made a cup out of a piece of paper or cardboard and successfully poured water into it without it disintegrating before your eyes? Yes, that’s right, never. You have never done this.

So, when you see ‘plastic-free’, fibre-based takeaway packaging, it’s not unreasonable to wonder - ‘what has given this product an anti-liquid superpower?’

Basically, packaging companies that make plastic-free, fibre-based serviceware add stuff to the packaging to make it behave like plastic, but without the plastic. We’re talking water repellent, non-stick coatings and wet strength additives. This is where things start to get alarming because achieving these outcomes for serviceware may rely on one of these two thingies:

Per- and polyfluoroalkyl substances (PFAS)
Water dispersion coating/aqueous coating

So, let’s look at these one at a time. Then, after that, we’ll have a look at these other things called Non-Intentionally Added Substances (NIAS) that may also be present in food packaging containing recycled fibre (whether that packaging is a composite product or a plastic-free product).

What is PFAS?

PFAS are a group of synthetic compounds commonly used in a wide range of products because of their resistance to heat, oil and water, e.g. non-stick cookware, cosmetics, firefighting foam, waterproof clothing and lots of food contact materials, including fibre-based food packaging, takeaway and fast-food packaging, and food papers like bakery and burger wraps.[8] While PFAS isn’t in all takeaway packaging, estimates from the North American context suggest it’s in about 50% of takeaway packaging and the tricky thing is that it’s very difficult to know which products it’s in and which it isn’t (many packaging suppliers don’t even know if it’s in their product).[9]

PFAS can be ‘long-chain’ or ‘short-chain’, which refers to their chemical and molecular structure and how many carbons are attached.[10] Long-chain PFAS have been more greatly regulated in recent years as research has uncovered their dangers.[11] Shorter-chain PFAS are less regulated, partly because they have a shorter half-life in the human body (so higher concentrations are needed to have the same adverse effects as the longer-chain versions). Given this lack of regulation, the use of shorter-chain PFAS is increasing.[12]

PFAS are bad for us

PFAS are known carcinogens and have a range of other adverse health impacts, including increasing cholesterol levels, creating hormone disorders, and disrupting immune systems (including decreasing people’s immune system response to vaccinations).[13] PFAS have been shown to transmit to food if contained in packaging.[14]

PFAS are bad for the soil

Would you scrape Teflon into your compost or water your compost down with fire-fighting foam?

PFAS can concentrate in the soil if compost that has been used to process PFAS-ridden products is continually applied to the same piece of land.

PFAS are persistent organic pollutants (POPs), i.e. they’re ‘forever chemicals’ that don’t break down in the environment and instead bioaccumulate over time.[15] As Ackerman et al. state: “since nature did not put these molecules together, it doesn’t know how to take them apart”.

Put that stuff in a compost and it gets into the soil and stays in the soil. The more a composter composts PFAS-ridden products, and then adds the finished compost to the same piece of land, the more the PFAS will concentrate in the soil,[16] and also in any earthworms doing their decomposing mahi.[17] A 2019 study in the US of nine commercial composts and one backyard compost found PFAS in all the composts, but commercial composts that accepted food packaging had ten times the amount of PFAS in the final compost than facilities that did not accept food packaging. To our knowledge, no such studies have yet been conducted in NZ, but we reckon it needs to be done, especially given the big uptake in fibre compostable serviceware.

To make matters worse, PFAS doesn’t just stay in the land or soil where it’s put - it’s highly mobile (especially shorter-chain PFAS), including in aquatic environments where it quickly dissolves into water. PFAS has been found in landfill leachate, compost sites and wastewater treatment plants,[18] and it’s evidently getting into groundwater. All of this means that…

PFAS get into the food chain

PFAS can be taken up by animals who graze on land where contaminated compost has been applied.

Unsurprisingly, PFAS is increasingly found in drinking water supplies at levels that exceed safe levels,[19] and even in dust and indoor air that people inhale.[20] PFAS can be taken up by animals who graze on land where contaminated compost has been applied, or who consume plants that have absorbed PFAS. As a result, PFAS has been found in meat, fish, eggs and dairy.[21]

It’s also been discovered that PFAS (especially the short-chain variety) can be taken up by plants, including vegetables and crops.[22] So, anyone using organic compost that has had that lovely plastic-free but potentially PFAS-ridden compostable packaging in it...? Yep, that could be getting into your veggies.

Just like in other living beings, PFAS accumulates in the human body. Around the world, tests have found PFAS in human blood serum and breast milk, often at levels that exceed those prescribed as safe by relevant regulatory authorities.[23] A recent study of American mothers’ breast milk found PFAS in all 50 samples tested, at levels 2000 times above the safe limit for drinking water.

And you know what should really piss you off? It was recently revealed that major chemical manufacturers knew, for over a decade, that certain types of PFAS used in food packaging are unsafe for human health, but actively suppressed this information from the public and regulators.

Water-based (aqueous) dispersion coating

OK, so that’s all very terrifying, but sadly, it’s not just PFAS that should keep us up at night - there’s also a relatively new kid on the packaging block called ‘water-based dispersion coating’ (WBDC), based on technology known as ‘aqueous polymeric dispersions’ (got your tongue around that one?). This is a coating that gets applied to fibres to create a liquid-proof barrier that, like PFAS, removes the need for fibre packaging to have a separate, solid plastic lining to stop liquids seeping through.

WBDC technology is being touted by some as the future of sustainable food packaging. Some have recognised the problems and dangers of PFAS and see WBDC as the best alternative. Fibre packaging treated with WBDC, like coffee cups and food containers, are claimed to be fully recyclable, compostable and even 100% plastic-free. Indeed, the packaging industry likes to emphasise the fact that they use a ‘water-based’ coating. No doubt, water is a much better medium than a synthetic solvent, and it makes the technology sound harmless. Yay for water!

But WAIT...

… adding water to paper in order to repel more water…?

We’re no detectives, but surely that doesn’t add up? Sounds like there might be a bit more going on than just water here...

The dead giveaway is that little “based” bit in “water-BASED”. WBDC is a water solution (the base) that has had grease- and water-repellent polymers (and various other chemical additives) suspended in it. A description of the resins that are typically invited to float around in WBDC is telling: “pure acrylic polymers, copolymers of acrylates such as ethyl acid acrylates and ethylene methacrylate, polyvinyl acetates, styrene butadiene copolymers, and polyolefins.”[24] It’s a who’s who of well-known plastic polymers.

As the American Chemistry Council notes in their thorough description of the “definition and properties of polymers,” ‘polymers’ is “another name for plastics.”

So HOW can these products be called ‘plastic-free’ if they have plastic in them?

It all depends on how plastic is defined in law. For example, some of these ‘plastic-free’ claims are made in the EU context where certain laws and regulations state that plastics are plastics when they are capable of functioning as ‘the main structural component’ of a finished product.[25] The nature of WBDC (as a dispersed coating) means it isn’t capable of acting as the ‘main structural component’ of the cup or container - therefore, magic! It’s not plastic!

Erm… so, as you can see, it’s a legal fiction that these products are plastic-free, not a physical reality.

Do we really want to put this in our composts? As one study noted, when paper cups with WBDC go through industrial composting they “leave behind thermoplastic microparticles, which can still have an adverse environmental impact.” Compost this stuff and you are literally adding microplastics to the soil.

What’s fascinating and disturbing is that some WBDC products have been certified compostable by reputable certification standards, even though the polymers often used in WBDC aren’t known for their biodegradability. This is likely because the volume of polymer in these coatings is low enough to fall below the minimum plastic thresholds to pass certification testing.[26]

Whether intentional or not, WBDC allows packaging companies to claim their product is plastic-free, recyclable and compostable according to the strict letter of the law, rather than the spirit.

Undoubtedly, WBDC has way smaller amounts of plastics than conventionally plastic-lined products. But do we want to knowingly add microplastics to our soils at any concentration? And what does this mean for human health? While the health implications of petrochemical resins are poorly understood, enough warning signs exist to demand extreme caution when adding anything of the sort to food and drink packaging,[27] let alone continuing to make this raft of petrochemical and plastic stuff in the first place.

Recycled paper and cardboard and Non-Intentionally-Added-Substances (NIAS)

If products with PFAS and water-based dispersion coatings are not composted, they may be sent for recycling instead. In fact, most fibre-based packaging is marketed as recyclable. Pizza boxes and brown paper bags are good examples, both of which could have water- and grease-resistant additives in them, like PFAS, or other wet-strength additives.

Recycling paper involves water - lots of it. The paper and cardboard swishes around in a great big soup, allowing any persistent organic pollutants (POPs) or microplastics that might be in any of the paper or cardboard products being recycled to transfer to the water, providing another avenue for these forever chemicals and bits of plastic to get into the waterways and natural environment.

This soupy slurry moment also creates an opportunity for harmful contaminants to transfer into all the paper and cardboard products being processed together in this batch of recycling.

If paper and cardboard can ‘catch’ PFAS, POPs and other chemicals of concern during the recycling process, then manufacturers who choose to make their products out of recycled paper and cardboard could find these chemicals in their final product, even if they never put them there. When this happens, the chemicals are called a Non-Intentionally-Added-Substance (NIAS).[28] Over time, we may see more and more NIAS in paper and cardboard, as a result of recycling.[29]

Compostable serviceware that contains recycled paper and cardboard may be introducing a wider range of chemicals into the food chain and soil (if composted), through NIAS. A 2013 German study attempting to assess the safety of recycled paperboard for food packaging came to the conclusion that the potential range of problematic substances that recycled paper is exposed to during the recycling process “is too large to realistically be brought under control”, making any reliable food safety assessment about recycled paperboard “unrealistic”.

This creates a dire dilemma: do we use recycled paper and cardboard and potentially spread these toxins far and wide through our bodies, composts and recycling; or do we seek to avoid NIAS by using only new paper/cardboard, which requires us to cut down more trees and deepen the climate crisis? It’s an impossible choice.

And while composting or recycling plastic-free packaging looks increasingly undesirable, binning it is no option either because these products produce large amounts of methane in landfill. Plus the toxins accumulate in the landfill leachate anyway.

Humans… we’ve managed to create a weird combination of a stalemate/own goal.

How do we know which compostable products are safe to use and compost, and which aren’t?

The short answer is – often you don’t. And that’s one reason why Takeaway Throwaways advocates avoiding all of it like the plague. Companies who want us to use their compostables need, at the very least, to step up and be transparent about what’s in them.

You shouldn’t really have to be a detective to work out if serviceware products allowed on the market are safe or not…

Right now, there is no legal requirement that the ingredients in packaging be clearly displayed on the package. Furthermore, New Zealand has no national standard for compostability and companies who use the word ‘compostable’ on their product are not required to have any certification to back that up.[30] Although, the Commerce Commission has indicated that companies claiming compostability for uncertified products risk violating the Fair Trading Act (p.13).

There are internationally recognised compostability standards that many responsible New Zealand companies do choose to certify against. However, even certified compostable products may still contain harmful additives because most of the tests don’t test for them, or because the additives in any particular product falls below certain threshold limits.

Many certifications and testings are being updated to reflect new evidence about the harms of PFAS.[31] The Biodegradable Products Institute will not grant its certification to any product with intentionally added fluorinated chemicals. The Compost Manufacturing Alliance in the US - who test compostable packaging on behalf of composters and create approved ‘lists’ for companies to refer to - have stated they won’t even test compostable packaging with fluorine above a certain level and will remove any previously approved packaging with fluorine levels exceeding this limit from their approved list. Companies are responding by developing PFAS-free fibre packaging.

While this is all good news, there are a bazillion more intentionally added food contact chemicals out there,[32] not to mention whatever comes in to fill the gap that a PFAS ban leaves behind, as well as all the NIAS. There are also more additives to be invented that we don’t know about yet. And as we’ve already mentioned, packaging companies don’t have to disclose what they are putting in their packaging anyway.[33]

In the world of packaging, the rate of innovation moves FAR FASTER than regulators, who struggle to control even the harmful chemicals we know about, let alone the ones we don’t know about, or are yet to discover. The current system for assessing the safety of food contact chemicals, combined with the ad hoc approach of banning chemicals after they have already been used and applied to soils for years, is failing to empower us to determine what’s safe and what isn’t, and failing to protect human and environmental health.[34]

Does this mean that conventional plastic packaging was better after all?

No, but you can bet your bottom dollar that the petroleum plastics industry will indeed make this argument to justify continuing to fill the world with single-use disposable plastics. However, the concerns surrounding the potentially harmful human impact of food contact chemicals apply to conventional plastics as well as compostable packaging.[35]

Single-use plastics aren’t off the hook just because single-use fibre products have their issues…

We don’t need to fall into this pointless ‘better and worse’ debate that only matters to those with a vested interest in particular materials. Rather, we should look at the bigger picture and see that the problem is the single-use, throwaway mentality, and put our money and our love behind the reuse horse - and non-toxic reusables at that (with toxicity being assessed with reference to latest evidence and research from relevant experts[36]).

When we spend time trying to work out which material is the ‘least bad’ in a single-use format, we’re missing the forest for the trees (and soon we’ll have neither forests nor trees if we carry on turning them into boxes, bags and cups). In fact, it’s precisely this thinking that has led us to embrace fibre-based compostable products that could be poisoning our soils, waterways and bodies.

So often we hear people say, ‘oh well, at least it’s better than...’ or ‘don’t criticise small steps in the right direction...’. What we’re trying to say here is that when you look into it, compostable packaging is not necessarily a better step in the right direction. Are items designed purely to make our lives more convenient really worth the risk?

We need to get out of single-use and switch to non-toxic reusables at scale.[37] This is completely possible for takeaway packaging, it just requires clear Government policy and investment. Because investment to avoid a waste crisis will come. We need that investment to support long-term reuse infrastructure, rather than the short-term ambulance at the bottom of the cliff that is attempted management of single-use packaging. As a species, we’ve achieved far more complicated things, like going to the moon, and inventing the internet and stuffed crust pizza. We can definitely work out how to wash and reuse cups, plates and knives and forks. Let’s just get on with it.

What needs to happen?

Many reforms are needed. Here’s a (non-exhaustive) list of things we’re calling on the Government to do:

Reassess the current policy settings for packaging that favour single-use. Policy, regulatory and investment levers need to be pulled, urgently, to enable the growth of reuse schemes for packaging, alongside phase-outs of single-use plastics and other efforts to regulate plastics. Scientifically-informed chemical safety assessments need to be developed to determine what reusables are safe to use for FCM.
Reassess the current regulatory focus on restricting single-use plastic packaging and expand the waste policy programme to address all packaging, regardless of material type. This will make it easier to avoid unintended consequences when targeting one material only, and to grow reuse as a realistic alternative to all single-use packaging.
Use s 23 of the WMA to phase-out the use of PFAS and WBDC in food packaging, while being aware that this action must occur in tandem with the actions above, to avoid companies simply shifting from PFAS and WBDC to other problematic chemical additives.
Use s 23 of the WMA to mandate labelling of all the ingredients in food packaging (whether single-use or reusable).
Institute a tightly regulated certification system for compostable packaging across material types. No packaging should be able to claim compostability status unless it complies with this certification. Ensure the standards test for a wide variety of potential residual contaminants that reflect the range of known food contact chemicals.
Redirect any current or planned government investment and support for compostable packaging and associated infrastructure towards developing safe and accessible reusable packaging systems and a robust food contact chemical safety assessment (which should be used to assess all food contact materials, including reusables).

Endnotes

[1] Miriam Gordon (2021) Reuse Wins: the environmental, economic, and business case for transitioning from single-use to reuse in food service (UPSTREAM). See also www.solvingpackaging.org.

[2] Ritson and Peake (2020) “The need to mitigate risks in moving to circular food contact materials” Environmental Scientist. February. Muncke, J., Andersson, AM., Backhaus, T., et al (2020) “Impacts of food contact chemicals on human health: a consensus statement” Environmental Health 19(25); Joe Ackerman, David McRobert and Meg Sears (2021) “PFAS on Food Contact Materials: Consequences for human health, compost, and the food chain and prospects for regulatory action in Canada and beyond” McGill Journal of Sustainable Development Law.

[3] Choi, Y. J., Lazcano, R. K., Yousefi, P., Trim, H., and Lee, L. S. (2019) “Perfluoroalkyl Acid Characterization in U.S. Municipal Organic Solid Waste Composts” Environmental Science & Technology Letters 2019 6 (6), p.372.

[4] Choi, Y. J., Lazcano, R. K., Yousefi, P., Trim, H., and Lee, L. S. (2019) “Perfluoroalkyl Acid Characterization in U.S. Municipal Organic Solid Waste Composts” Environmental Science & Technology Letters 2019 6 (6).

[5] Muncke, J., Andersson, AM., Backhaus, T., et al (2020) “Impacts of food contact chemicals on human health: a consensus statement” Environmental Health 19(25); Ritson and Peake (2020) “The need to mitigate risks in moving to circular food contact materials” Environmental Scientist. February.

[6] Ibid.

[7] Ritson and Peake (2020) “The need to mitigate risks in moving to circular food contact materials” Environmental Scientist. February, p.15.

[8] Minnesota Pollution Control Agency “Composting and PFAS”; Choi, Y. J., Lazcano, R. K., Yousefi, P., Trim, H., and Lee, L. S. (2019) “Perfluoroalkyl Acid Characterization in U.S. Municipal Organic Solid Waste Composts” Environmental Science & Technology Letters 2019 6 (6), p.372.

[9] Joe Ackerman, David McRobert and Meg Sears (2021) “PFAS on Food Contact Materials: Consequences for human health, compost, and the food chain and prospects for regulatory action in Canada and beyond” McGill Journal of Sustainable Development Law.

[10] American Water Works Association (2019) Per- and Polyfluoroalkyl Substance (PFAS) Overview and Prevalence, p.1.

[11] Ibid.

[12] Choi, Y. J., Lazcano, R. K., Yousefi, P., Trim, H., and Lee, L. S. (2019) “Perfluoroalkyl Acid Characterization in U.S. Municipal Organic Solid Waste Composts” Environmental Science & Technology Letters 2019 6 (6), p.373; Costello and Lee (2020) “Sources, Fate, Plant Uptake in Agricultural Systems of Per- and Polyfluoroalkyl Substances” Current Pollution Reports; Joe Ackerman, David McRobert and Meg Sears (2021) “PFAS on Food Contact Materials: Consequences for human health, compost, and the food chain and prospects for regulatory action in Canada and beyond” McGill Journal of Sustainable Development Law.

[13] American Water Works Association (2019) Per- and Polyfluoroalkyl Substance (PFAS) Overview and Prevalence, p.2; Britt E. Erickson (2020) “EU agency sets limit on PFAS in food” (17 September) Chemical and Engineering News; Joe Ackerman, David McRobert and Meg Sears (2021) “PFAS on Food Contact Materials: Consequences for human health, compost, and the food chain and prospects for regulatory action in Canada and beyond” McGill Journal of Sustainable Development Law; Ritson and Peake (2020) “The need to mitigate risks in moving to circular food contact materials” Environmental Scientist. February.

[14] Joe Ackerman, David McRobert and Meg Sears (2021) “PFAS on Food Contact Materials: Consequences for human health, compost, and the food chain and prospects for regulatory action in Canada and beyond” McGill Journal of Sustainable Development Law.

[15] Costello and Lee (2020) “Sources, Fate, Plant Uptake in Agricultural Systems of Per- and Polyfluoroalkyl Substances” Current Pollution Reports.

[16] Choi, Y. J., Lazcano, R. K., Yousefi, P., Trim, H., and Lee, L. S. (2019) “Perfluoroalkyl Acid Characterization in U.S. Municipal Organic Solid Waste Composts” Environmental Science & Technology Letters 2019 6 (6), p.372.

[17] Joe Ackerman, David McRobert and Meg Sears (2021) “PFAS on Food Contact Materials: Consequences for human health, compost, and the food chain and prospects for regulatory action in Canada and beyond” McGill Journal of Sustainable Development Law.

[18] Minnesota Pollution Control Agency “Composting and PFAS”.

[19] American Water Works Association (2019) Per- and Polyfluoroalkyl Substance (PFAS) Overview and Prevalence; Britt E. Erickson (2020) “EU agency sets limit on PFAS in food” (17 September) Chemical and Engineering News; Choi, Y. J., Lazcano, R. K., Yousefi, P., Trim, H., and Lee, L. S. (2019) “Perfluoroalkyl Acid Characterization in U.S. Municipal Organic Solid Waste Composts” Environmental Science & Technology Letters 2019 6 (6), p.373; Sarah Gibbens (2020) “Toxic ‘forever chemicals’ more common in tap water than thought, report says” (25 January) National Geographic.

[20] Costello and Lee (2020) “Sources, Fate, Plant Uptake in Agricultural Systems of Per- and Polyfluoroalkyl Substances” Current Pollution Reports.

[21]Choi, Y. J., Lazcano, R. K., Yousefi, P., Trim, H., and Lee, L. S. (2019) “Perfluoroalkyl Acid Characterization in U.S. Municipal Organic Solid Waste Composts” Environmental Science & Technology Letters 2019 6 (6), p.372.

[22] Costello and Lee (2020) “Sources, Fate, Plant Uptake in Agricultural Systems of Per- and Polyfluoroalkyl Substances” Current Pollution Reports.

[23] Britt E. Erickson (2020) “EU agency sets limit on PFAS in food” (17 September) Chemical and Engineering News; Agency for Toxic Substances and Disease Registry “PFAS Blood Testing”; Costello and Lee (2020) “Sources, Fate, Plant Uptake in Agricultural Systems of Per- and Polyfluoroalkyl Substances” Current Pollution Reports.

[24] Triantafillopoulos, N., & Koukoulas, A. A. (2020) "The future of single-use paper coffee cups: Current progress and outlook," BioRes. 15(3), 7260-7287.

[25] These ‘plastic-free’ claims are made on slide 6 of the following slideshow: https://www.ausderwildnis.fi/wp-content/uploads/2019/01/kotkamills.pdf; based on the following laws: Directive (EU) 2019/904 of the European Parliament and of the Council of 5 June 2019 on the reduction of the impact of certain plastic products on the environment; and Commission Regulation (EU) No 10/2011 of 14 January 2011 on plastic materials and articles intended to come into contact with food.

[26] Although such certifications are usually quite thorough, they do have some concerning elements such as, “The total sum of the organic compounds for which biodegradability need not be determined may not exceed 5 % of mass.” See Din Certco (Oct 2017). Certification Scheme: Products made of compostable materials (DIN-Geprüft), according to DIN EN 13432, if applicable, in connection with DIN EN 14995 ISO 17088, ISO 18606, AS 4736. TÜV Rheinland.

[27] See e.g. Azoulay, D. et al. (Feb 2019). Plastic & Health: The Hidden Costs of a Plastic Planet. Centre for International Environmental Law (CIEL).

[28] Curtzwiler et al (2020) “Significance of Perfluoroalkyl Substances (PFAS) in Food Packaging” Integrated Environmental Assessment and Management 17(1).

[29] See, for example, Ritson and Peake (2020) “The need to mitigate risks in moving to circular food contact materials” Environmental Scientist. February, p.17.

[30] Kim Renshaw (2021) Consultation: The use-case for Compostable Packaging in New Zealand (The Packaging Forum).

[31] Choi, Y. J., Lazcano, R. K., Yousefi, P., Trim, H., and Lee, L. S. (2019) “Perfluoroalkyl Acid Characterization in U.S. Municipal Organic Solid Waste Composts” Environmental Science & Technology Letters 2019 6 (6), p.372.

[32] Muncke, J., Andersson, AM., Backhaus, T., et al (2020) “Impacts of food contact chemicals on human health: a consensus statement” Environmental Health 19(25); Ritson and Peake (2020) “The need to mitigate risks in moving to circular food contact materials” Environmental Scientist. February; Joe Ackerman, David McRobert and Meg Sears (2021) “PFAS on Food Contact Materials: Consequences for human health, compost, and the food chain and prospects for regulatory action in Canada and beyond” McGill Journal of Sustainable Development Law.

[33] Joe Ackerman, David McRobert and Meg Sears (2021) “PFAS on Food Contact Materials: Consequences for human health, compost, and the food chain and prospects for regulatory action in Canada and beyond” McGill Journal of Sustainable Development Law; Ritson and Peake (2020) “The need to mitigate risks in moving to circular food contact materials” Environmental Scientist. February.

[34] Muncke, J., Andersson, AM., Backhaus, T., et al (2020) “Impacts of food contact chemicals on human health: a consensus statement” Environmental Health 19(25).

[35] Ibid; Ritson and Peake (2020) “The need to mitigate risks in moving to circular food contact materials” Environmental Scientist. February.

[36] Muncke, J., Andersson, AM., Backhaus, T., et al (2020) “Impacts of food contact chemicals on human health: a consensus statement” Environmental Health 19(25).

[37] Miriam Gordon (2021) Reuse Wins: the environmental, economic, and business case for transitioning from single-use to reuse in food service (UPSTREAM). See also www.solvingpackaging.org.

Is compostable serviceware actually safe for people and planet? Part 1: A focus on fibre