PFAS and PPWR: are you compliance-ready for 12 August 2026?

Per- and polyfluoroalkyl substances (PFAS) are a broad group of substances. In a food-packaging supply chain, packaging may involve substrates, barriers, coatings, inks, varnishes, glues, adhesives and other components. Whether a particular component is relevant depends on the actual packaging unit and its intended use.

Article 5(5) sets the following maximum PFAS concentration limits for food-contact packaging:

• 25 ppb for any individual PFAS, measured using targeted PFAS analysis, excluding polymeric PFAS from the calculation.
• 250 ppb for the sum of PFAS, measured using targeted analysis and, where applicable, following degradation of precursor substances, excluding polymeric PFAS.
• 50 mg/kg for total PFAS, including polymeric PFAS.

The Commission FAQ describes Article 5(5) as a set of maximum concentration levels. It also explains that the limits apply to the packaging unit as a whole, including associated inks, varnishes, glues and adhesives placed on the market by the manufacturer, without distinguishing between intentionally added and unintentionally present PFAS.

Article 5(5) concerns food-contact packaging. Apply the Regulation and relevant food-contact-material rules to the particular packaging and intended use rather than relying on a broad characterisation.

The Commission FAQ contains further explanations about who is the manufacturer and when packaging is placed on the market in different supply-chain scenarios. Seek case-specific legal advice where those facts determine an operator’s obligations.

The manufacturer is responsible for the applicable conformity assessment. Annex VII requires technical documentation, including an appropriate analysis and assessment of non-compliance risks and, where relevant:

• A description of the packaging and intended use.
• Information on design, manufacture and component materials.
• Relevant standards, specifications and methods.
• The means used to meet applicable requirements.
• Test reports.

The manufacturer must draw up an EU declaration of conformity under Article 39. The applicable retention period is generally five years for single-use packaging and ten years for reusable packaging.

The Commission says it is working toward a harmonised testing protocol. It describes total-fluorine and total-organic-fluorine analysis as possible enforcement starting points; neither should be treated as a single conclusive legal compliance test.

Businesses can prepare by:

• 1. Mapping food-contact packaging across the product portfolio.
• 2. Identifying the manufacturer and any importer for each arrangement.
• 3. Listing associated components and the supplier information available for them.
• 4. Requesting specifications, declarations and relevant technical evidence.
• 5. Reviewing whether evidence matches the finished packaging unit and intended use.
• 6. Maintaining records when materials, formulations, manufacturing or suppliers change.
• 7. Obtaining competent technical and legal advice where the evidence or testing approach needs assessment.

TakeawayPack can help buyers organise supplier information, request documentation, compare packaging structures and coordinate samples, drawings and records. It cannot certify compliance or issue an EU declaration of conformity on a manufacturer’s behalf.