From 12 August 2026, food-contact packaging must not be placed on the market with PFAS at or above the applicable PPWR thresholds: 25 ppb for an individual targeted PFAS, 250 ppb for the targeted sum and 50 ppm for PFAS including polymers. These are separate limits.
PFAS under the PPWR: a requirement applying since 12 August 2026
The PFAS restriction is not postponed until 2030. Article 5(5) of the PPWR provides that, from 12 August 2026, food-contact packaging must not be placed on the market if PFAS concentrations equal or exceed the specified limits, to the extent that another EU legal act does not already prohibit packaging containing those concentrations.
1. The first threshold: 25 ppb
The 25 ppb threshold applies to an individual PFAS measured by targeted PFAS analysis. Polymeric PFAS are excluded from quantification for this particular threshold.
2. The second threshold: 250 ppb
The 250 ppb threshold applies to the sum of PFAS determined by targeted analyses, with prior degradation of precursors where applicable. Polymeric PFAS are also excluded from quantification for this threshold.
3. The third threshold: 50 ppm
The 50 ppm threshold covers PFAS including polymeric PFAS. If total fluorine exceeds 50 mg/kg, the relevant manufacturer, importer or downstream user under REACH must, on request, provide the packaging manufacturer or importer with evidence of the quantity of fluorine attributable to PFAS or non-PFAS substances for the technical documentation.
Total fluorine and PFAS content are therefore not interchangeable results. A fluorine measurement needs to be interpreted within the evidential requirement rather than automatically treated as a measurement of total PFAS.
4. What counts as food-contact packaging?
This covers packaging intended to contact food, or already in contact with food and intended for that purpose, within the scope of EU food-contact-material legislation. The assessment should not automatically be limited to plastic packaging.
The Commission’s August 2026 FAQ explains that the assessment covers the packaging unit as a whole, including its inks, varnishes, glues and adhesives. The restriction covers both intentionally added PFAS and PFAS present unintentionally.
5. A lack of one harmonised method does not remove the obligation
The absence of one common EU analytical method does not mean the requirement can be disregarded. A company needs a reliable analytical approach and a documented explanation of how compliance has been assessed, taking account of applicable current guidance and methods.
6. Who should gather the data?
The work will generally involve packaging, quality, purchasing and regulatory teams, alongside suppliers of materials, coatings, barriers, paper, inks, varnishes and other components relevant to the result.
7. What evidence may be needed?
- Raw-material and component specifications.
- Supplier declarations and supporting information.
- Analytical test results.
- Identification of the packaging version.
- The test method and scope of analytes.
- Documented risk assessment.
- A link between the evidence and the current stock-keeping unit, or SKU.
8. PFAS and food-contact legislation apply alongside each other
The PPWR does not replace Regulation (EC) No 1935/2004, Regulation (EU) No 10/2011 or other food-contact-material safety requirements. Meeting the PFAS limits does not complete the material's conformity assessment.
9. PFAS and recycled content are separate matters
The rPET or other recycled-material percentage does not answer the question of PFAS compliance. Equally, a PFAS result does not establish the PCR content or recyclability of the packaging.
10. An example qualification process
- Identify food-contact packaging.
- Identify components potentially relevant to PFAS.
- Collect supplier information.
- Assess the need for testing.
- Link the result to the correct packaging version.
- Record the assessment in the technical documentation.
- Control changes to materials and suppliers.
11. Manufacturing date and first placing on the market
The Commission’s guidance does not provide a stock-exhaustion period merely because packaging was manufactured before 12 August 2026. Food-contact packaging first placed on the market from that date must meet the limits. Packaging already placed on the market before that date may remain available; this requirement does not itself require its withdrawal. There is no exemption for packaging containing recycled material.
The key principle
PFAS is a current requirement, not a plan for 2030. For food-contact packaging placed on the market from 12 August 2026, this subject belongs in the company's current compliance system.
Frequently asked questions
Does the 50 ppm limit replace the 25 and 250 ppb limits?
No. The PPWR establishes three separate concentration limits with different analytical scopes. Compliance with one does not establish compliance with the others.
Does the requirement apply only to plastic?
No. Article 5(5) addresses food-contact packaging within its stated scope, rather than only plastic packaging.
Is a supplier declaration always sufficient?
No. The evidence required depends on risk, material type, the method used and the reliability of the data. Its adequacy must be assessed for the packaging concerned.
Does the absence of intentionally added PFAS establish compliance?
No. The restriction also covers PFAS present unintentionally.