From 12 August 2026, binding PFAS limit values for food packaging apply under Article 5(5) of the PPWR. Important: the PPWR does not contain a general PFAS ban. But it sets maximum concentrations for packaging that is intended to come into contact with food. We tell you which food packaging is particularly affected, which limit values apply, when a laboratory test is advisable and how to provide the required evidence.
Which Packaging is Affected?
The PFAS (per- and polyfluoroalkyl substances) limit values primarily affect primary packaging and packaging components with direct food contact. However, what is decisive is not whether a material is generally considered a food contact material, but whether it actually comes into physical contact with the food as intended as part of the packaging.
Potentially PFAS-relevant items may therefore include in particular:
- Plastic cups, bottles, stand-up pouches and their food-contacting components
- Inner layers of multi-layer composites
- Paper-based to-go packaging, paper bags, wrapping papers and inserts
- Food-contacting coatings, internal lacquers, sealing films and lid interior coatings
- Paper and cardboard boxes, if they come into direct contact with food without an inner bag or film.
- Printing inks, lacquers, adhesives and coatings, insofar as they form part of the relevant packaging unit.
Not affected are generally components without intended food contact, for example
- Outer labels,
- outer lid components,
- secondary packaging,
- transport packaging,
- shrink films, or
- other ancillary components without direct contact with the food matrix.
Which Limit Values Apply?
Article 5(5) of the PPWR specifies three limit values:
- 25 ppb (parts per billion) for individually targeted PFAS
- 250 ppb for the sum of targeted PFAS, after degradation of precursor compounds where applicable
- 50 ppm for PFAS including polymeric PFAS, measured via total fluorine content
If a total fluorine content of 50 mg/kg is exceeded, it must be possible to demonstrate what proportion is attributable to PFAS or to non-PFAS.
How Should Conformity be Demonstrated?
A blanket testing regime for all packaging is neither practicable nor technically sensible. Analytical capacities are limited and harmonised EU testing methods for all packaging matrices are not yet available.
A compliance-by-design approach is therefore recommended: companies should manage material selection, specifications, supplier requirements and manufacturing processes so that PFAS risks are minimised at source.
The evidence should be risk-based and encompass three elements:
- Exclude intentional PFAS use through supplier declarations along the relevant supply chain.
- Assess unintentional inputs, for example from processing aids, lubricants or cleaning agents, recycled precursors or cross-contamination.
- Assess material risk depending on whether PFAS could have a known technical function in the respective material group, for example in certain paper, coating or barrier applications.
On this basis, a documented risk matrix should be created. It determines whether supplier declarations, specifications, audits, targeted laboratory tests or regular monitoring are required.
When is a Laboratory Test Advisable?
Laboratory tests should be used in a targeted manner, particularly when supply chains are not transparent, supplier declarations are missing, source materials vary significantly, recycled materials are used or existing stocks need to be assessed.
The EU Commission recommends a step-by-step approach for this:
- First, the total fluorine content is determined.
- If this is below 50 mg/kg, the sample can be considered to be in conformity.
- If it is above this, it should be checked whether the fluorine is organic or inorganic.
- Only if a risk continues to exist may a more extensive analysis be required (such as a TOP analysis to check the limit values of 25 ppb or 250 ppb respectively).
Who is Responsible?
The responsible party for PFAS conformity determination is generally the producer as defined in the PPWR. Important: the producer as defined in the PPWR is frequently not the physical packaging manufacturer, but the company that has packaging or a packaged product developed or manufactured under its own name or brand.
BP Consultants Recommendation
Companies should now delineate their affected packaging portfolio:
- Which packaging is intended to come into contact with food?
- Which components actually come into contact with the food?
- Which coatings, printing inks, lacquers or adhesives form part of the relevant packaging unit?
Building on this, a documented risk assessment process should be established. Supplier declarations, material and process assessments, and targeted tests form the basis for making PFAS conformity demonstrable. The PFAS assessment should be maintained as a separate component of the PPWR conformity documentation. For an overview of the latest guidance documents published by the European Commission, as well as other national developments, please also refer to our article “PPWR Blog: Guidance, FAQs and National Requirements”.
If you still need to establish structures for supplier management, declarations of conformity or technical documentation at short notice, our “PPWR Late Starter Package – Fast, Pragmatic and Structured” provides a practical implementation framework to help you achieve compliance efficiently.
