PFAS — per- and polyfluoroalkyl substances — are a family of ~15,000 synthetic chemicals widely used in foodservice packaging since the 1960s for grease and moisture resistance. They’ve also been linked to a long list of human health harms and don’t break down in the environment. Five US states (CA, NY, ME, MN, WA) have enacted bans on intentional PFAS additions to foodservice packaging, with more in active consideration. This guide covers what’s affected, what “PFAS-free” actually means, and how to source compliantly.
The state-level PFAS bans in foodservice
| State | Bill | Effective | Coverage |
|---|---|---|---|
| Maine | LD 1503 | 2023 | All food packaging |
| Minnesota | HF 2310 | 2024 | All food packaging |
| Washington | SB 5135 | 2023 | Food packaging (phased by category) |
| California | AB 1200 | 2023 | Plant-based food packaging |
| New York | A4392 | 2023 | Food packaging |
| Connecticut | SB 837 | 2024 | Food packaging |
| Colorado | HB22-1345 | 2024 | Food packaging |
| Vermont | S 25 | 2023 | Food packaging |
| Maryland | HB 275 | 2024 | Food packaging |
| Rhode Island | H 7438 | 2024 | Food packaging |
Several other states have introduced PFAS-in-packaging bills that are still in process. The trend line is clear — PFAS bans on foodservice packaging are spreading faster than EPS foam bans did.
Which foodservice products historically contained PFAS
PFAS was used to add grease resistance to PAPER and FIBER products specifically. Categories most affected:
- Grease-resistant paper wraps (fast-food sandwich wraps, burger wraps)
- Microwave popcorn bags (PFAS was a primary use case for decades)
- Pizza boxes (grease-resistant variants)
- Paper plates (rated for hot food)
- Fiber and molded pulp clamshells (bagasse with PFAS grease coating)
- Compostable fiber bowls (especially “biodegradable” lines pre-2024)
- Paper bags rated for greasy/oily food (subset of kraft bag market)
Categories that never used PFAS (or used it minimally):
- All plastic packaging (PET, PP, MFPP, HDPE)
- Aluminum foil and aluminum pans
- Plain uncoated kraft paper (no grease resistance claim)
- EPS foam (not relevant — foam is intrinsically grease-resistant via cell structure)
A practical implication: aluminum + plain plastic + uncoated kraft is the easiest PFAS-compliant packaging stack to source. No vendor certification needed because the materials never used PFAS.
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Aluminum Containers
8 SKUs · from $18.71 – $56.38 per case
What “PFAS-free” actually guarantees
The legal definition varies by state, and the testing methodology matters more than buyers realize.
“No intentional PFAS” — the manufacturer did not add PFAS to the product. Trace amounts (from contamination, raw materials, manufacturing equipment) may exist below a detection threshold. This is the more common claim and aligns with most state law language.
“PFAS-free” (strict) — typically defined as below a specific ppm threshold (often 100 ppm total fluorine). This is a stricter claim and requires third-party testing.
Most state laws use a “100 ppm total fluorine” or “no intentionally added” threshold. Some states (Maine especially) are moving toward stricter “any detectable PFAS” standards.
For sourcing, ask vendors for:
- A signed statement of compliance with the relevant state laws (most major brands have these on file)
- Third-party PFAS test results (a Certificate of Analysis from an accredited lab)
- Explicit grease-resistance technology disclosure (clay-based coating, silicone, PHA — whichever they use as PFAS replacement)
A vendor who can’t provide all three for a paper or fiber product should be treated with skepticism.
What replaced PFAS
The industry has moved fast to develop PFAS alternatives. Three main classes are in production:
Clay-based barrier coatings. Mineral clay particles bonded into the paper or fiber matrix create a grease-resistant barrier. Cost: ~10-20% premium over plain paper. Performance: moderate to good grease resistance, weaker moisture resistance.
Silicone coatings. Food-grade silicone applied as a thin coating. Cost: ~15-30% premium. Performance: very good grease resistance, decent moisture resistance, but not industrially compostable (silicone doesn’t break down).
PHA / PLA polymer linings. A thin bioplastic film bonded to the paper or fiber. Cost: ~30-50% premium for PLA-lined fiber. Performance: good both grease and moisture, industrially compostable.
The PHA/PLA option is the best fit for compostable-mandate markets. Clay is the best fit for cost-sensitive operations that need grease resistance but don’t need compostability. Silicone is a niche choice for premium operations.
Operator action items
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Audit which of your SKUs are paper or fiber-based with grease resistance claims. Plastic, aluminum, and uncoated kraft are automatically compliant. The audit-priority list is grease-resistant paper wraps, fiber clamshells, fiber plates, and grease-resistant pizza boxes.
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Request PFAS-free certification from your distributors on each in-scope SKU. A good distributor will have these on file or can request from the vendor within 1-2 weeks. If a distributor can’t produce certification within 30 days, that’s a signal.
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Build a transition plan if you discover non-compliant SKUs. Most states allow 6-12 months from discovery to remediation if you’re acting in good faith. Don’t try to use up legacy non-compliant inventory in regulated markets — fines can apply.
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Don’t over-pay for “PFAS-free” plastic. Plastic packaging is PFAS-free by nature. If a vendor charges a premium for “PFAS-free PET clamshells,” they’re charging you for nothing — PET clamshells never had PFAS.
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Watch federal regulation. The FDA has been moving on PFAS for foodservice paper for several years. A federal rule would standardize state requirements and may push the regulatory bar higher than the state-level patchwork.
Summary by state (cheat sheet)
| State | PFAS-in-packaging ban | Effective | Threshold |
|---|---|---|---|
| Maine | ✅ | 2023 | ”Any intentional addition” |
| Minnesota | ✅ | 2024 | ”No intentionally added” |
| Washington | ✅ | 2023 (phased) | Phased by category, 100 ppm threshold |
| California | ✅ | 2023 | Plant-based packaging, 100 ppm |
| New York | ✅ | 2023 | No intentional addition |
| Connecticut | ✅ | 2024 | No intentional addition |
| Colorado | ✅ | 2024 | No intentional addition |
| Vermont | ✅ | 2023 | No intentional addition |
| Maryland | ✅ | 2024 | No intentional addition |
| Rhode Island | ✅ | 2024 | No intentional addition |
| Pending (introduced) | MA, MI, NJ, OR, PA, VA | Various | TBD |
(Verify current status with your state environmental quality department before making procurement decisions — this regulatory area is moving quickly.)