PFAS in food packaging – what does PPWR change?

PFAS in food packaging – what changed on 12 August 2026?

The PPWR has turned the PFAS issue into a direct packaging conformity requirement. Food-contact packaging may not be placed on the market if its PFAS content reaches or exceeds one of the limit values referred to in Article 5(5), taking into account the relationship of that provision with other acts of Union law.

This is significant from the perspective of the conformity procedure. Article 15 of the PPWR requires the manufacturer to place on the market only packaging that complies with the relevant requirements of Articles 5–12. Compliance with the PFAS restriction therefore becomes one of the requirements to be considered when assessing a given type of packaging, if it is intended for food contact.

The date of 12 August 2026 should not, however, be equated with all PPWR obligations. Many other requirements concerning, among other things, recyclability, minimisation and recycled content have later deadlines. The PFAS restriction in Article 5(5), however, is one of the requirements relevant from the general date from which the Regulation applies.

What are PFAS and why do they arise in the context of food packaging?

PFAS are a broad group of perfluoroalkyl and polyfluoroalkyl substances. The PPWR gives them particular attention due to their persistence and potential impact on the environment and human health.

In food-contact materials, certain compounds from this group have been used, among other things, for their hydrophobic and oleophobic properties. They could help limit the penetration of grease or moisture through the material.

Therefore, areas requiring attention may include, for example, certain barrier papers and boards, takeaway packaging, wraps, cartons, baking papers, multilayer materials and other food-contact solutions.

The use of a specific material alone does not prove the presence of PFAS. The assessment should concern the specific packaging variant, its composition, coatings, layers and data from the supply chain.

Which packaging is covered by the PFAS restriction in the PPWR?

Article 5(5) applies to food-contact packaging. It is therefore not a general PFAS limit for every box, film or industrial package.

The intended use of the packaging is key. In practice, before assessing PFAS, it must first be determined whether a given type of packaging actually falls within the food-contact category.

What PFAS limits does PPWR introduce? 25 ppb, 250 ppb and 50 ppm

PPWR does not use a single universal PFAS threshold. Article 5(5) provides for three limit values relating to different methods of determining substances.

These values are alternative restriction conditions. A company should therefore not check only one parameter if the method used does not make it possible to demonstrate compliance with the other applicable criteria.

50 ppm PFAS is not the same as 50 mg/kg of total fluorine

This is one of the most important distinctions when interpreting laboratory results. Measuring total fluorine can be a very useful screening tool, but fluorine itself does not have to originate exclusively from PFAS.

Article 5(5) includes a mechanism relating to situations where the total fluorine content exceeds 50 mg/kg. In such cases, it must be possible to demonstrate what proportion of the measured fluorine is attributable to PFAS and what proportion may originate from sources other than PFAS.

Therefore, a report containing only a “total fluorine” result should not, without additional analysis, be interpreted as a direct result of PFAS content.

Does the restriction cover only PFAS intentionally added to packaging?

The assessment should not be limited only to substances knowingly added by the manufacturer. The current European Commission FAQ explains that the restriction should also be considered in relation to PFAS present unintentionally.

This is relevant to the supply chain. The material manufacturer may declare that it ‘does not intentionally use PFAS’, but such a statement is not exactly the same as demonstrating that the finished packaging complies with the specific PPWR concentration limits.

The risk of unintentional presence may depend, among other things, on raw materials, the manufacturing process, the use of recycled material, cross-contamination and other elements of the production process.

When do the PFAS limits apply and what does ‘placing on the market’ mean?

The restriction in Article 5(5) applies from 12 August 2026.

The concept of placing on the market is important in this context. In the PPWR, it is linked to the first making available of the packaging concerned on the Union market.

For this reason, the date on which packaging is manufactured and the date on which it is placed on the market need not be the same event. When assessing stocks, the actual status of the specific goods in the supply chain must be established.

What about packaging manufactured before 12 August 2026?

It should not automatically be assumed that a production date before 12 August 2026 in itself creates an indefinite exemption from the new requirements.

Recital 14 of the PPWR indicates that packaging already placed on the market before the relevant requirements start to apply, and subsequently held in the warehouses of distributors or retailers, should not have to comply with the new requirements.

A different situation arises where packaging was physically manufactured earlier, but would only be placed on the market for the first time after the restriction starts to apply.

The Commission’s current explanations also concern the practical approach of authorities to enforcing the new requirements, but they should not be regarded as postponing the application date of Article 5(5) or as a universal stock depletion period.

Must every food packaging item be laboratory-tested for PFAS?

The PPWR does not establish a simple obligation to carry out an identical laboratory test for every batch of every packaging item.

However, the manufacturer must have sufficient evidence to demonstrate the compliance of a specific packaging type with the applicable requirements.

Depending on the product, evidence may include, among other things:

• laboratory test results,
• material specifications,
• information on formulation and coatings,
• supplier documentation,
• statements concerning the use of PFAS,
• a risk assessment based on reliable data,
• test results for a representative variant, where their applicability to the assessed type can be reliably demonstrated.

The greater the uncertainty as to the composition or the risk of PFAS use, the stronger the evidential basis that a reliable assessment may require.

How should PFAS be tested in packaging when there is no single harmonised EU method?

As at the date of publication of this article, there is no single harmonised Union test method that addresses all aspects of verifying the PFAS limits under Article 5(5).

The European Commission’s updated FAQ of August 2026 refers to analytical practice and the control approach. In the area of PFAS, this may include, among other things, tests targeting specific compounds, precursor analyses and fluorine determinations used as part of a broader assessment.

This does not mean, however, that every available method is automatically equivalent. When commissioning tests, the laboratory should know that the objective is to demonstrate compliance specifically with the thresholds in Article 5(5) of the PPWR.

It is advisable to retain in the documentation not only the final result, but also the method used, the scope of substances determined, the limits of quantification and the sample preparation method.

What PFAS-related documents should be requested from a packaging supplier?

Article 16 of the PPWR requires suppliers of packaging or packaging materials to provide the manufacturer with the information and documentation needed to demonstrate compliance.

In the case of PFAS, a well-prepared request to a supplier should concern a specific material or variant, rather than the company’s entire catalogue.

How to check a PFAS test report before including it in PPWR documentation?

Having a laboratory report alone is not sufficient. It must be established whether the report can actually serve as evidence for the packaging being assessed.

Check in particular:

• full sample identification,
• the code and version of the tested material,
• the date the sample was taken or received,
• the method used,
• the list of PFAS analysed,
• limits of detection and quantification,
• how the result is reported,
• whether precursors were analysed, where relevant,
• whether the result can be compared with the relevant PPWR threshold,
• whether the material or production process was changed after testing.

A report concerning an anonymous “paper food packaging” sample does not have the same evidential value as a report clearly linked to the currently purchased material and its revision.

Is a supplier’s “PFAS free” statement sufficient?

Not always. First, it must be established what exactly the supplier means by “PFAS free”.

It may mean, for example:

• no intentionally added PFAS,
• absence of a specified group of PFAS,
• a result below the limit of quantification of a specific method,
• compliance with specific PPWR limits.

These are different claims. Therefore, the statement should indicate at least the material to which it applies, the scope of the declaration, the basis for its issue and the product version.

If the supplier refers to testing, it is worth obtaining the report or sufficient information on the test method and scope.

Who is responsible for packaging compliance with PFAS limits?

In the PPWR compliance system, the manufacturer has a key role. In accordance with Article 15, the manufacturer may place on the market only packaging that meets the relevant requirements of the Regulation.

The supplier is required to provide the necessary information and documentation, but this does not automatically mean that it assumes the manufacturer’s responsibility for the final assessment.

The importer, in turn, has its own obligations under Article 18, including verifying whether the manufacturer has carried out the conformity assessment procedure and drawn up the required documentation.

Therefore, before establishing a PFAS process, you need to correctly determine the company’s role in the supply chain.

How should PFAS be documented in PPWR technical documentation?

Annex VII requires technical documentation to enable the assessment of the packaging’s conformity with the applicable requirements.

For PFAS, the documentation should create a logical chain of evidence:

packaging type → material → intended for food contact → Article 5(5) requirement → assessment method → evidence → result → conclusion on conformity.

If the company bases its assessment on a supplier’s report, the documentation should demonstrate why that report relates to the specific packaging type.

If an assessment based on several sources has been used – for example, a specification, supplier declaration and laboratory test – it is also advisable to retain the links between them.

Must the PFAS test result be included in the PPWR declaration of conformity?

The EU declaration of conformity is not a laboratory report. Its purpose is to formally confirm that compliance with the applicable PPWR requirements has been demonstrated.

Detailed reports, results and justifications belong primarily in the technical documentation forming the basis for the declaration.

If Article 5(5) applies to the packaging concerned, the manufacturer should be able to move from the declaration to documentation showing the basis on which the PFAS requirement was considered fulfilled.

A declaration alone, without available supporting evidence, does not resolve the conformity issue.

PPWR does not replace legislation on food contact materials

Food-contact packaging is subject to several legal systems at the same time.

PPWR expressly takes into account the relationship between packaging legislation and other acts of Union law, including rules on materials and articles intended to come into contact with food.

Regulation (EC) No 1935/2004 is of fundamental importance, among others. Depending on the material and intended use, more specific legal acts may also be relevant.

Compliance with PPWR does not automatically mean compliance with all FCM legislation, and vice versa.

However, documentation received from a supplier for the purposes of other regulations may form part of the evidence used in the PPWR assessment.

A change of supplier, coating or formulation may require reassessment of PFAS

A test result should not be retained indefinitely without checking whether it still relates to the current product.

In particular, the following may require reassessment:

• a change of material supplier,
• a change of base paper or plastic,
• a change of barrier coating,
• a change of adhesive or additive,
• a change of formulation,
• a change in the recycled content,
• a change in the manufacturing process that may affect composition.

A change-control mechanism should form part of the PPWR documentation management system.

PFAS and PPWR – practical conformity checklist

1. Determine whether the packaging is intended to come into contact with food.
2. Identify the exact type, variant and version of the packaging.
3. Gather the full material specification.
4. Check layers, coatings and additional components.
5. Ask the supplier for information on PFAS.
6. Determine whether the supplier refers to the absence of intentionally added PFAS or compliance with PPWR limits.
7. Gather test reports, where available.
8. Check whether the methods and limits of quantification allow the result to be assessed against Article 5(5).
9. Do not automatically equate total fluorine with PFAS content.
10. Assess whether the available evidence is sufficient.
11. If necessary, commission additional testing or analysis.
12. Record how compliance is demonstrated in the technical documentation.
13. Link the documentation to the relevant EU declaration of conformity.
14. Establish the supplier’s obligation to notify changes.

Most common mistakes when demonstrating PFAS compliance

• treating „we do not add PFAS” as full confirmation of compliance with Article 5(5);
• failure to identify the material in the laboratory report;
• confusing total fluorine with PFAS content;
• checking only the 25 ppb threshold;
• no information on the range of substances analysed;
• using a report relating to an outdated formulation;
• treating a supplier declaration as a substitute for your own conformity assessment;
• storing a report without linking it to a specific packaging type;
• assuming that all packaging manufactured before 12 August 2026 is automatically exempt;
• treating FCM compliance as automatic confirmation of compliance with the PPWR.

How do you manage PFAS evidence for multiple packaging types?

For one or two materials, documentation can be managed manually. With a larger portfolio, however, issues with versions, suppliers, reports and deadlines quickly arise.

One report may relate to several variants, but only if the company can justify that link. Conversely, a single change to a coating may require many packaging types to be reviewed again.

Managing the relationship between the requirement, material, evidence and specific packaging type therefore becomes crucial.

PFAS in food packaging – key conclusions

From 12 August 2026, PFAS limits are a real part of the conformity assessment of packaging intended to come into contact with food.

The rules establish three reference levels: 25 ppb, 250 ppb and 50 ppm. However, the compliance process should not be reduced to a single figure or test. The scope of analysis, sample identity, polymeric PFAS, potential precursors and the interpretation of total fluorine must be taken into account.

In practice, a sound process starts with full packaging identification and supplier data, then proceeds through an assessment of the available evidence, and ends with the technical documentation and EU declaration of conformity.

This enables the company to answer not only „do we have a PFAS report?”, but also „why does this report actually confirm the compliance of this specific packaging?”.

FAQ – PFAS in food packaging and the PPWR

Sources

Legal basis: Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste – EUR-Lex

European Commission guidelines: Commission Notice C/2026/3084 – Guidelines on Regulation (EU) 2025/40

Current European Commission FAQ: Packaging and Packaging Waste Regulation (PPWR) – Frequently Asked Questions, DG Environment

Food contact materials legislation: Regulation (EC) No 1935/2004 – EUR-Lex

The article draws in particular on:

• Article 5(5) of the PPWR – restriction on PFAS in food contact packaging,
• Article 15 – obligations of manufacturers,
• Article 16 – suppliers’ information obligations,
• Article 18 – obligations of importers,
• Article 38 – conformity assessment procedure,
• Article 39 – EU declaration of conformity,
• Annex VII – technical documentation and conformity assessment procedure,
• Annex VIII – structure of the EU declaration of conformity.