PPWR PFAS concentration limits for food-contact packaging: what manufacturers should prepare for by 12 August 2026

The PPWR is Regulation (EU) 2025/40. The Commission FAQ explains that Article 5(5) is a restriction based on maximum concentration levels, not a PFAS prohibition. It applies to food-contact packaging placed on the EU market.

The restriction does not distinguish between intentionally added and unintentionally present PFAS. The FAQ states that it applies to the packaging unit as a whole, including associated inks, varnishes, glues and adhesives placed on the market by the manufacturer.

Food-contact packaging must remain below each applicable limit:

• 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.

These are PFAS concentration limits; they should not be confused with results from a broad fluorine screen. Packaging at or above an applicable limit must not be placed on the EU market from 12 August 2026.

PFAS-related evidence may be relevant to the finished packaging unit and its associated components, such as barriers, coatings, inks, varnishes, glues and adhesives. The appropriate scope depends on the packaging design and supply chain.

A practical preparation file may include:

• 1. A packaging inventory and component list.
• 2. Supplier specifications and declarations with a clearly stated scope.
• 3. Information on material or formulation changes.
• 4. Relevant test reports and methods where appropriate.
• 5. The manufacturer’s technical documentation and conformity-assessment record.

The Commission says it is working toward a harmonised testing protocol. Total-fluorine or total-organic-fluorine analysis may be an enforcement starting point, but should not be treated as conclusive proof of compliance. Select methods with competent technical and legal advice.

The manufacturer carries the legal responsibility for the applicable conformity assessment and EU declaration of conformity. 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.

Businesses should identify their role for each packaging arrangement instead of using broad labels such as “brand owner” as a substitute for the Regulation’s defined roles.

Under Article 62, where a Member State identifies non-compliance, it must first require the relevant economic operator to end it. If non-compliance persists, further measures may include prohibition, recall or withdrawal, subject to the PPWR and applicable national enforcement arrangements.

TakeawayPack can help buyers request, organise and compare material, structure, coating and supplier-documentation information across cups, bowls, boxes, containers, trays, lids, bags and cutlery. It can coordinate samples, drawings and records for review.

TakeawayPack cannot certify PPWR compliance or issue an EU declaration of conformity on behalf of a manufacturer.