From 12 August 2026, the Packaging and Packaging Waste Regulation (EU) 2025/40 prohibits placing food-contact packaging on the market when per- and polyfluoroalkyl substances (PFAS) reach any of three concentration thresholds. The lowest sits at 25 parts per billion for any individual non-polymeric PFAS, measured by accredited laboratory analysis. Packaging already placed on the EU market before that date and sitting in distributor stock is not affected; newly placed packaging faces no transition window, and proof of compliance lies with the manufacturer. For paper-based food packaging, moulded fibre trays, and grease-resistant liners, this is the most disruptive single-substance restriction in EU packaging history.
What is the PPWR PFAS Ban?
Article 5 of PPWR prohibits placing food-contact packaging on the EU market when it contains PFAS in concentrations equal to or above defined thresholds. PFAS, sometimes called "forever chemicals", are a class of around 10,000 synthetic substances valued for grease, water and stain resistance. In packaging they appear in fluorochemical coatings on paper trays, pizza boxes, microwave popcorn bags, fast-food wrappers and moulded fibre tableware. The ban applies from 12 August 2026 with no transition period.
The Three Concentration Thresholds
Unlike a single-number ban, PPWR sets three nested limits. A packaging item must pass all three:
| Threshold | Limit | Scope | Test method |
|---|---|---|---|
| Individual non-polymeric PFAS | 25 ppb (μg/kg) | Each single PFAS substance, measured separately | Targeted analysis (LC-MS/MS) |
| Sum of non-polymeric PFAS | 250 ppb (μg/kg) | Total of all detected non-polymeric PFAS | Targeted analysis |
| Total PFAS (including polymeric) | 50 ppm (mg/kg) | All PFAS as measured by total organic fluorine | TOF / EOF screening, then targeted confirmation |
The 25 ppb limit is what most labs flag during routine screening. The 250 ppb sum catches cumulative low-level contamination across multiple PFAS species. The 50 ppm total-PFAS ceiling catches polymeric PFAS (PTFE, fluoropolymers) that escape targeted methods, which is why a two-step analytical workflow is becoming standard: total organic fluorine first, targeted confirmation second.
What Counts as "Food Contact" Packaging?
Food-contact packaging means any packaging that comes into direct contact with food during normal use, plus packaging that may transfer constituents to food under foreseeable conditions. Inner liners of a cardboard box that touches the food count. The outer cardboard typically does not, unless it is in direct contact (no inner barrier) or has been shown to migrate through the barrier.
In practice, the scope catches:
- Quick-service restaurant wrappers, clamshells, and paper bowls.
- Moulded fibre tableware (plates, trays, cups).
- Microwave popcorn bags.
- Pizza boxes where the inner layer contacts the pizza.
- Pet food packaging in direct contact with kibble or wet food.
- Baking paper, muffin liners, and parchment.
- Single-use cups for hot and cold beverages.
- Direct-contact paper wraps for meat, cheese, fish, and bakery products.
Why 25 ppb is Lower Than It Looks
25 ppb is a strict threshold by analytical chemistry standards. To detect that level reliably, laboratories typically need a method limit of detection (LOD) of 5 ppb or lower, which puts the test in liquid chromatography tandem mass spectrometry (LC-MS/MS) territory. Costs per sample run between EUR 250 and EUR 800 depending on the number of PFAS targeted (the EU "PFAS-20" panel is a common starting point).
The thresholds apply to the measured concentration, whatever its origin: Article 5(5) draws no distinction between intentional use and background contamination. In practice, staying below the limits requires a clean supply chain audit. PFAS contamination of recycled paper fibre is a known issue, with deinking processes failing to remove fluorinated coatings from the input stream. Manufacturers relying on recycled fibre for food-contact applications need to source from PFAS-free recovered streams or risk failing the 250 ppb sum threshold even without intentional addition.
Documentation Required for Compliance
Test results live in the Annex VII technical file backing the Declaration of Conformity. Specifically:
| Document | Detail |
|---|---|
| Certificate of Analysis (CoA) | From ISO/IEC 17025 accredited laboratory, per packaging type, per supplier batch where material composition changes |
| Method description | Targeted PFAS panel used, LODs, sample preparation |
| Supplier declaration | Statement of no intentional PFAS addition, signed by raw material supplier |
| Migration data (where relevant) | For multi-layer packaging where PFAS-containing layer is not in direct contact |
| Audit trail | Sampling plan, frequency, change-control procedure |
A single supplier change, ink change, or coating change triggers retesting. Manufacturers running monthly converter audits typically build a six-month rolling test calendar to keep documentation current.
Alternatives to PFAS Coatings
Replacing PFAS grease and water barriers without losing functional performance is the hard part. The mature alternatives by 2026 include cellulose-based bio-coatings, alkyl ketene dimer (AKD) and styrene-maleic anhydride (SMA) sizings, polyhydroxyalkanoate (PHA) and polylactic acid (PLA) extrusion coatings, and bentonite-clay coatings for grease resistance. Each has trade-offs: PHA and PLA add cost, AKD requires reformulation per substrate, and clay coatings can affect machinability.
For some applications, the answer is reformulating the packaging concept entirely: replacing a fluorinated paper boat with a moulded fibre tray plus PHA film, or with reusable foodservice ware where the local context allows. Reusable systems also align with the broader PPWR reuse targets coming into force from 2030.
Enforcement Outlook
Market surveillance authorities in Germany, France, the Netherlands and the Nordics already test food-contact packaging for PFAS under existing national rules (notably Denmark's 2020 ban). PPWR harmonises the threshold across the 27 Member States, which means a CoA accepted in Berlin is accepted in Lisbon. National enforcement priorities will likely target high-volume QSR formats, fibre tableware imported from outside the EU, and recycled-fibre food packaging where contamination risk is highest. Penalties follow the Member State implementation pattern: administrative fines, mandatory recall, and in repeat cases, marketing bans for the operator.
Supply chain pressure is already visible. Quick-service restaurant chains and major retailers have been issuing PPWR supplier requirements since mid-2025, pulling forward the effective deadline for their converters by six to twelve months. Converters that cannot produce a clean PFAS test report put their customers in a difficult position well before the 12 August 2026 date, since the brand owner needs the evidence in its own Annex VII file.
Working with the Supply Chain
The single biggest failure mode in PFAS compliance is opaque multi-tier supply. A printed paper tray might involve a fibre mill, a coater, a converter, and a printer, with the PFAS risk sitting two or three tiers upstream of the brand. Bringing the chain into compliance means cascading PPWR supplier questionnaires beyond Tier 1, ideally with contractual right-to-audit clauses. Some brands are running joint testing programmes with their converters to share the cost and accelerate qualification.
Documentation has to follow the goods. Each batch of food-contact packaging shipped after August 2026 needs to be traceable back to the test report that covers its material composition. Lot codes printed on the packaging become the bridge between physical product and the technical file backing the Declaration of Conformity.
PFAS Testing in the PPWR + DPP Workflow
From 2028, the harmonised label and data carrier on packaging open the door to attaching test certificates digitally. Brands building a DPP for packaging can host PFAS CoAs behind the QR code, giving recyclers and authorities a one-scan verification path. The same approach is being used for substances of concern in batteries, see the battery passport guide for the precedent.
Frequently Asked Questions
Does the PFAS ban apply to packaging manufactured before August 2026?
It depends on when the packaging is placed on the market, not when it is manufactured. Packaging first placed on the EU market on or after 12 August 2026 must meet the PFAS thresholds. Recital 14 of Regulation (EU) 2025/40 states that packaging already placed on the Union market before that date, sitting in the stocks of distributors, retailers or wholesalers, does not need to meet the sustainability requirements — including the Article 5(5) PFAS thresholds — even if it is sold later.
Are polymeric PFAS like PTFE covered?
Yes, through the 50 ppm total PFAS ceiling measured by total organic fluorine. Polymeric PFAS escape targeted LC-MS/MS analysis, so the regulation includes a broader screening method to catch them. PTFE-based release coatings used in baking applications fall in scope.
What testing frequency do market surveillance authorities expect?
PPWR does not prescribe a frequency. Industry practice converges on initial qualification per packaging type, then routine testing tied to supplier or formulation changes. Many converters adopt a six- to twelve-month rolling retest calendar for high-volume food-contact products.
Can recycled paper be used for food-contact packaging under PPWR?
Technically yes, but the manufacturer carries the burden of proving that the recycled stream does not push PFAS levels above the thresholds. In practice, food-contact applications increasingly use virgin or audited closed-loop recycled fibre to avoid contamination from PFAS-coated input material.