PPWR PFAS concentration limits in food-contact packaging: checking adhesive-related evidence

The Article 5(5) limits for food-contact packaging are:

• 25 ppb for any individual PFAS, measured using targeted PFAS analysis.
• 250 ppb for the sum of PFAS, measured using targeted analysis.
• 50 mg/kg for total PFAS, including polymeric PFAS.

The restriction does not distinguish between intentionally added and unintentionally present PFAS. Packaging at or above an applicable limit must not be placed on the EU market from 12 August 2026.

A finished pack can include substrate, coatings, inks, varnishes, glues, adhesives, labels and other components. The Commission FAQ expressly identifies associated inks, varnishes, glues and adhesives in describing the packaging unit.

That does not establish that a particular component or adhesive type contains PFAS, or that it meets a limit. The relevant question is whether the manufacturer has evidence appropriate to the actual packaging unit and its intended food-contact use.

If you specify or procure food-contact packaging, a focused request can cover:

• 1. The packaging structure and each relevant component.
• 2. The scope and date of material specifications and declarations.
• 3. Whether the information covers associated inks, varnishes, glues and adhesives.
• 4. Information on formulation, component or supplier changes.
• 5. Relevant technical evidence and test reports where appropriate.
• 6. The identity of the manufacturer responsible for the conformity assessment and EU declaration of conformity.

The Commission says it is working toward a harmonised testing protocol. It describes total-fluorine and total-organic-fluorine analysis as a starting point for enforcement. Select an appropriate method with competent technical and legal advice rather than treating a single screen as conclusive proof of compliance.

The manufacturer must draw up an EU declaration of conformity in accordance with Article 39, supported by the technical documentation required under Annex VII. That documentation may include, where relevant, packaging and material information, standards or specifications, methods and test reports.

For imported packaging, Article 18 requires the importer to verify, among other things, that the non-EU manufacturer carried out the conformity assessment and drew up the EU declaration of conformity.

TakeawayPack can help buyers request and organise material, structure and coating information; coordinate samples and drawings; and compare manufacturer documentation across a range of food-service packaging. It cannot certify compliance or issue an EU declaration of conformity on behalf of a manufacturer.