FDA's request this week for information on per- and polyfluoroalkyl substances (PFAS) in seafood is part of the agency's investigation into the potential health impact of PFAS exposures, which may be higher in seafood according to sample data.

The agency is calling for scientific data and information from the seafood industry, academia, state and federal agencies, and allied entities on PFAS concentrations in seafood, the surrounding environment and water, in addition to strategies for reducing PFAS exposure in seafood.

PFAS were once considered useful for food packaging to resist heat, oil, stains, grease and water. However, its proximity to food raises health concerns about ingesting PFAS, in addition to concerns over the chemicals seeping into soil and water from landfills.

To date, 13 states are phasing out PFAS in food packaging, including California, Colorado, Connecticut, Hawaii, Maine, Maryland, Minnesota, New Hampshire, New York, Oregon, Rhode Island, Vermont and Washington.

Earlier this year, an FDA import alert warned the agency could detain imported products with detectable levels of PFAS along with a range of synthetic contaminants.

FDA's call for input is also followed by its recent decision earlier this month to remove 23 phthalates used in flexible, durable and transparent food packaging from food-contact uses. This decision means that safety around phthalates will be assessed individually rather than as a group - which brought a mix of industry support and objections, as reported previously by FoodNavigator-USA.

Plastic recycling programs in the US are limited, with less than 9% of all plastic materials being successfully recycled, according to the Consumer Brand Association. The organization emphasizes molecular recycling as a viable solution to broaden the current recycling program to include low density plastics like films, flexible packaging and colored plastics, which can be used to create "like-new building blocks for plastic products."

American Chemistry Council argues that advanced recycling technologies could reduce environmental costs significantly, estimating them at $71 billion compared to up to $183 billion for alternative solutions.

However, bioplastics, like polyhydroxyalkanoates (PHAs) made from engineered bacteria and organic biomass serve as another potential solution to improve packaging sustainability. Yet the sector must first overcome barriers like high production costs, limited infrastructure and regulatory confusion, according to experts.

FDA collects samples and tests for PFAS through a variety of ways, including through the agency's Total Diet Study (TDS), which monitors nutrient levels and contaminants in foods eaten in the US.

To build on TDS findings, FDA conducted additional seafood surveys in 2021 and 2022, though data remain limited for many seafood types.

In 2022, FDA published analytical results from its seafood survey, which analyzed 81 samples purchased at retail for 20 types of PFAS between 2021 and 2022. This survey included mostly imported fish and shellfish (clams, cod, crab, pollock, salmon, shrimp, tuna and tilapia) in a variety of packaging, including canned, paper and foil pouches. At least one type of PFAS was detected in 60 samples, with high levels of perfluorooctanoic acid (PFOA) detected in clams and determined to be a health concern.

FDA determined that the "estimated" high levels of PFOA in canned clams were imported from China and a "likely health concern," particularly for consumers who eat more than approximately 10 ounces of these products per month, excluding young children who should only consume two ounces per month. PFOA exposure is linked to several adverse health outcomes, including developmental changes, altered liver function, weakened immune response and increased risk of certain types of cancer, according to FDA.

The two distributors of the samples containing the highest levels of PFOA voluntarily recalled the products. The first firm recalled all products within the identified Universal Product Code (UPC). The second also recalled its canned clam products in FDA's survey.

Comments regarding PFAS in seafood can be submitted electronically on Regulations.gov to docket number FDA-2024-N-4604 by Feb. 18, 2025.