The proposal to „include an optional approach as section 4.1.3“, in which materials without added PFAS can be labeled as such, must be strongly rejected. Standardized, recognized international test methods must be used in conjunction with an international limit value. Since the limit values in the United States of America and the European Union are currently under intense discussion, short-term labeling free of PFAS in materials for food contact („no added PFAS in food zone materials“) cannot be implemented. Once the legislation establishes appropriate limit values, the section on labeling would no longer make sense. The ANSI/NSF 51 and ANSI/NSF 170 documents would then have to be revised again to delete the section on short-term labeling and the definition of PFAS.
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