A first-of-its-kind framework released on December 6th offers recommendations to food and food packaging companies on how to identify and evaluate nanomaterials in products.  Not only is this technology unregulated and untested for its implications on public health, but companies may not even be aware if they are using products made with nanomaterials.

The Sourcing Framework for Food and Food Packaging Products Containing Nanomaterials from As You Sow presents what companies should ask their suppliers regarding the safety of products containing nanomaterials, therefore allowing businesses to make more informed decisions.

Nanotechnology is the science of manipulating matter at the molecular scale to build structures, tools, or products.  This emerging science offers many new opportunities for food industry applications, such as nutritional additives, stronger flavorings and colorings, or antibacterial ingredients for food packaging.  However, these same properties have also raised safety concerns yet to be fully understood.

“Currently, most food companies do not have processes in place to identify if there are nanomaterials in their products, or to confirm the safety of those products,” says Amy Galland, Research Director of As You Sow and co-author of the Framework. “We are urging the food industry to utilize the precautionary principle and stay ahead of the regulatory curve on this issue.”

McDonald’s, major CPGs consulted

In consultation with food companies such as: Kraft, McDonald’s (which has adopted a “no nano” policy), Whole Foods, Yum! Brands, and Pepsi, the nonprofit organization As You Sow developed this practical tool which clearly outlines what companies should ask their suppliers regarding the safety of products containing nanomaterials.

“In the absence of federal regulations, corporations need to evaluate the risks and benefits of sourcing products that use this new technology on their own,” says Michael Passoff, Senior Strategist of As You Sow and co-author of the Framework.  “There is little transparency regarding safety testing or which food products contain nanomaterials. Companies need to start questioning their suppliers on whether or not their products use nanomaterials.”

In June 2011, the Food and Drug Administration stated it would evaluate guidance to address nanotechnology.  This guidance is not prescriptive and does not advise companies in how to protect their customers from exposure to nanomaterials.  There is also a lack of scientific research about how nanomaterials interact at the molecular and physiological levels, with unknown potential impacts on public health and the environment.

Consequently, companies looking to purchase or sell nanofood products or packaging have to take specific steps to protect themselves from financial and reputational risks through a thorough evaluation of the safety of these products, and transparency to address consumer concerns.

  Specifically, the Framework:

• Provides an introduction to key terms and issues by outlining a definition of nanomaterials; addressing the accessibility of nanoparticles within the human body and current studies which point to potential hazards; tackling the issue of unique properties and related, under-researched toxicity threats; and assessing how federal agencies are determining nanomaterial toxicological profiles.


• Describes the current regulatory status and risks including: recent developments on nanomaterials by the Environmental Protection Agency and the Food and Drug Administration; and the emerging concerns due to lack of regulation.


• Presents best practices from existing scientific, industry, and governmental frameworks including questions to ask suppliers to increase transparency of their supply chain and priorities for obtaining data related to risk and toxicity factors.


• Makes recommendations regarding the information companies should request and receive from suppliers who offer food products and packaging that may contain nanomaterials.

The Framework will be distributed widely throughout the food and food packaging industries and will be followed up by a survey asking these same companies to disclose what, if any, nanomaterials are being used in their supply chain.

As You Sow is a nonprofit organization that promotes corporate responsibility through shareholder advocacy, coalition building, and innovative legal strategies. For more information visit: www.asyousow.org