# Food Contact Paperboard: There Is No Such Thing as Food Grade _The federal rule permits named substances in the food-contact surface rather than defining a grade, and the PFAS change everyone calls a ban was a market exit the agency recorded._ **The short answer** **There is no food grade for paperboard.** The rule lists substances allowed in the food-contact surface, each one with its own limits. **The PFAS change was not a ban.** Makers stopped selling the coatings, the agency recorded that as abandonment, and 35 clearances lapsed on that basis. A drawing that asks for food grade board has named nothing, because no such grade exists and no standard sets one. What exists is a federal list of substances a food-contact surface may contain, each entry carrying its own limits. The list also sits behind a limit on what the finished surface gives up into food. The part most drawings now get wrong is newer than that list. Grease-proof coatings holding PFAS left the US market, and almost everyone calls the change a ban. It was not a ban. Makers stopped selling them, the agency recorded the stopping as abandonment, and 35 clearances lapsed as a result of that record. This reference covers what the rule is, what the PFAS record says, which category the agency singled out as a concern, and what the record leaves unanswered. Each of those points changes what a buyer can honestly write on a drawing. - **No grade** - There is no food grade for board - **35** - Clearances that lapsed, on abandonment - **4 categories** - PFAS food-contact uses, one of concern - **June 2025** - When existing stocks were expected gone ## There Is No Food Grade The [governing rule](https://www.ecfr.gov/current/title-21/chapter-I/subchapter-B/part-176/subpart-B/section-176.170) covers components of paper and paperboard that touch aqueous and fatty foods. Its opening line says the substances it identifies may be safely used in the food-contact surface. So the rule works by permission rather than by grade. A substance appears on the list, with limits attached, or it does not appear at all. Dry food takes a different route, because where the contact is with dry food of one named type, a separate section rules it instead. The limits themselves are tied to two things. Entries point at food types by numeral and at conditions of use by letter, and the rule carries tables for both. The list also sits behind a gate. A listed substance may go in the surface only if that surface meets the extractives limits the rule sets out further on. Which is where a practical problem starts. Those tables and limits do not appear in the rule's own web text, so a buyer reading it online sees the permissions and not the numbers. A grade name will not fill that gap either, since kraftliner vs testliner describes measured properties, and a property floor says nothing about what a board may contain. ## What the PFAS Change Actually Was In February 2024 the agency [announced](https://www.fda.gov/food/process-contaminants-food/market-phase-out-grease-proofing-substances-containing-pfas) that substances containing PFAS were no longer being sold into the US market as grease-proofing agents on paper food packaging. Read that sentence closely, because every load-bearing word in it is commercial. Makers stopped selling, and nothing in it forbids anything. The agency credits three things for the outcome: voluntary phase-out pledges from makers, an earlier rule change, and choices by makers to stop selling the rest. Only one of the three is a rule change, and it is older than the rest, since a 2016 revocation pulled the clearances for long-chain versions. The short-chain exit ran on a schedule instead. Three makers agreed in July 2020 to a three-year phase-out beginning January 2021. By 2023 the makers of every remaining cleared product said they had stopped selling it for food contact in the US. So the market closed the door and the agency wrote it down, which is a different act from banning a substance. > Figure: One rule change in sixty years, and a commercial exit the agency recorded rather than ordered. ## Abandonment Is the Mechanism In January 2025 a Federal Register notice ruled that 35 food contact notifications for these uses are no longer effective. The stated basis is abandonment. Makers ceased production, supply or use, and the agency treats that stopping as the reason the clearances lapse. Abandonment is worth a close look because of what it does not need, since no finding of harm, no rulemaking and no ban appear anywhere in the route. The clearances themselves have a long history. They date from the 1960s, and notices of this kind became the main form from 1999. That history explains why the count is 35 rather than one, because each one covered a single substance and use, so the exit had to happen 35 times. The agency's own table puts it plainly, logging the clearances as revoked due to abandonment, which states the same route as an outcome. For a spec the useful reading is narrow. Those 35 routes have closed, and the closing rests on market choices rather than on a rule change. ## Paper Is the Category the Agency Singled Out PFAS uses in food contact fall into four groups by the agency's [own count](https://www.fda.gov/food/chemicals/authorized-uses-pfas-food-contact-applications). Three of them read much the same. Making the part removes or burns off nearly all the smaller molecules, leaving tiny amounts able to reach food. | Application category | What the agency says about it | | --- | --- | | Nonstick coatings | Processing vaporizes off virtually all migratable molecules; negligible amounts can migrate | | Gaskets and seals on processing equipment | Processing removes virtually all migratable molecules; negligible amounts | | Manufacturing aids in other polymers | Only negligible amounts can migrate from this use | | Grease-proofing on paper food packaging | The one category where dietary exposure "may result in a potential safety concern" | The fourth group is the one on paper. These coatings went on fast-food wrappers, microwave popcorn bags, take-out board cartons and pet food bags. And the agency splits it from the other three without hedging. Only paper and board agents, it says, would result in dietary exposure that may result in a potential safety concern. That line is why the paper exit happened and the others did not, because the split turns on what reaches food rather than on the chemistry alone. The same list reaches molded pulp packaging as well, because molded fiber trays sit in the same contact space. ## What the Record Does Not Say Five absences matter more to a drawing than anything the announcement contains. There is no prohibition. Nothing in the record forbids the substances, so a supplier holding old stock has broken no rule. No test rule came with the change either. The record asks nobody to check anything, which leaves a PFAS-free claim resting on a supplier's word. Existing stock gets one line and no rule. For the short-chain products the agency expected stocks to last until June 2025, and says nothing about packs already in the chain. Imports go unmentioned entirely, since the exit covers what makers stopped selling into the US market rather than what arrives inside a finished pack. And the 35 notifications are never named, so a buyer cannot check a supplier's claim against a list that the agency has not published. One more gap sits in the agency's own pages. The introduction dates the announcement to February 2024 while the table says January 2024, and nothing reconciles them. So a food-contact spec has to do the work the phrase food grade only seems to do. Name the rule, and ask the supplier for a letter written against it. Then ask for the two things the record leaves to you: a statement on grease-proofing substances, and a date for the stock that statement covers. Treat corrugated box styles as a reminder that construction matters too, since a stitched joint puts metal inside the box and rules it out for food. And keep regulated shipments in their own lane, where an insulated shipper R-value and the product's own storage rules apply rather than this list. ## Common Questions ### Is there a food grade for paperboard? No. The federal rule lists substances allowed in the food-contact surface, each with its own limits. The surface also has to meet the rule's extractives limits. A drawing should name the rule rather than a grade. ### Did the FDA ban PFAS in food packaging? No. In February 2024 the agency said the grease-proof coatings were no longer being sold into the US market, after voluntary phase-out pledges and a 2016 revocation covering long-chain versions. The record sets out no ban. ### What does abandonment mean here? That makers ceased production, supply or use. In January 2025 the agency ruled 35 food contact notifications are no longer effective on that basis, with no finding of harm and no new rulemaking behind it. ### Can a PFAS-free claim be checked against the rule? Not from the public record. The 35 are not named, no test rule follows the change, and nothing covers stock already in the chain beyond a view that short-chain stocks would last to June 2025. **How to weigh this page.** The rule's shape comes from the current text of the federal rule, read directly, and the dates and wording of the exit from two of the agency's own pages. This is guidance for writing a spec, not a safety check on any product, and it draws no conclusion about whether any pack is safe. Three things stay out on purpose. The extractives limits, the food-type table and the conditions-of-use table do not appear in the rule's web text across two full passes, so no figure from them appears here. The dry-food section's numbers turned up only in a 2001 edition, which is too old to quote. State packaging laws were not read, so this covers the federal record only. **Key takeaways** - No food grade exists for board. The rule allows named substances in the food-contact surface, each with its own limits. - Permission also depends on the finished surface meeting extractives limits that the rule's own web text does not show. - The PFAS change was a market exit the agency wrote down, not a ban it issued. - Abandonment is the mechanism: makers ceased production, supply or use, and 35 food contact notifications stopped being effective on that basis. - Paper is the one group the agency says carries dietary exposure that may result in a potential safety concern.