FPA Provides Feedback to Massachusetts’ State House Regarding the House Language Regulating PFAS in Consumer Products (Formerly Amendment #447 of H.5510)

The Flexible Packaging Association (FPA) appreciates the opportunity to provide feedback regarding the House language regulating PFAS in consumer products (formerly amendment #447 of H.5510). While FPA fully supports the underlying goal of protecting public health and managing environmental safety, several provisions in the current draft pose significant operational complexities that depart from established, workable PFAS frameworks adopted by other states. Specifically, the current definition of “intentionally added” introduces a highly subjective standard that differs from existing regional frameworks governing food packaging. As currently drafted, this language may inadvertently restrict trace, unintentional contact and disrupt the supply chain for essential consumer and food packaging in the Commonwealth due to the administrative and operational requirements it establishes. FPA believes that addressing these provisions will help prevent unintended supply chain disruptions and maintain the affordability and safety of essential goods for Massachusetts residents.