Regulators assess the chemicals used in food packaging one at a time — a system researchers now say is failing consumers on a massive scale. A peer-reviewed study published September 1 in Environmental Science & Technology proposes a practical alternative: grouping chemicals by structural similarity to flag risks even where hard safety data doesn’t exist.

The study, led by scientists at the Food Packaging Forum, lands amid growing scrutiny of the more than 15,000 chemicals used in food contact articles, from packaging to kitchenware — 87% of which lack sufficient safety data to evaluate potential health impacts.

A regulatory system built for scarcity

The researchers argue that today’s substance-by-substance approach, used across Europe and North America, was never designed to keep pace with a chemical universe this large. Of the 15,000-plus substances in circulation, 1,222 have already been identified as priority chemicals hazardous to human health, while more than 13,000 others have little or no publicly available data to determine their safety.

To close that gap, the team built a method that groups chemicals sharing structural features — on the logic that similar structures often carry similar hazard properties. Applying it, the study identifies 38 priority chemical groups containing a disproportionately high number of known hazardous substances, including ortho-phthalates, PFASs, organophosphates, isocyanates, and primary aromatic amines.

The regrettable substitution problem

The findings carry a pointed warning for manufacturers navigating restrictions on legacy chemicals. In total, 4,222 food contact chemicals fall within the 38 flagged groups — meaning many substances currently on the market sit structurally close to known hazards and risk becoming “regrettable substitutes” if used as swap-ins.

“Replacing known hazardous chemicals with very similar but insufficiently tested alternatives is not solving the problem,” said Helene Wiesinger, lead author of the study. She noted the grouping method allows for rapid identification of chemicals of concern, giving both policymakers and industry a faster route to informed action.

Co-author Jane Muncke was more direct about the current system’s shortcomings. “Today’s regulatory approaches in Europe and North America look at each chemical individually, but this is inefficient and does not sufficiently protect consumers. We are proposing an evidence-based grouping approach decision makers can already use now until the proper testing methods and testing data become available.”

Free tools aim to speed adoption

Rather than leaving the approach as academic theory, the researchers released two practical tools alongside the study: an updated FCCprio List ranking known hazardous food contact chemicals, and FCCgroup, an interactive application that lets users screen their own chemical inventories against the 38 priority groups.

Albert Anguera Sempere, another co-author, framed the tool’s value in commercial terms as much as public health ones. He said FCCgroup is built to make it easy and quick for anyone to screen a set of chemicals and identify which might be hazardous — something he said could help companies get ahead of future legal restrictions, avoid litigation, and better protect their customers.

With regulators in the EU and US both signalling interest in reforming food contact material rules, a free, structure-based screening tool changes the risk calculus around substitution decisions. Companies swapping out a restricted chemical for a “similar” one without checking where it falls in these 38 groups may be trading one liability for another — and now have a way to check before they commit.