PFAS restrictions in food packaging according to PPWR
Regulation (EU) 2025/40, commonly known as the Packaging and Packaging Waste Regulation (PPWR), entered into force in February 2025 and is the core legal instrument redesigning the lifecycle of packaging in Europe. A key pillar of this regulation is Article 5, which governs the restriction of substances of concern. Its objective is to protect human health, minimize environmental impact, and ensure high-quality material circularity.
Particularly critical for the industry is the focus on PFAS (per- and polyfluoroalkyl substances) in food contact materials.
Effective date: 12 August 2026 – Direct applicability
The new requirements will become directly applicable in all EU Member States on 12 August 2026. For manufacturers, importers, and brand owners, this creates an urgent need to review material selection, strengthen supply chain management, and ensure comprehensive technical documentation.
Specific limit values for PFAS in food packaging
Under Article 5(5) of the PPWR, food contact packaging may no longer be placed on the market as of the deadline if it reaches or exceeds the following threshold values:
| Test Parameter | Limit Value | Scope |
| Individual PFAS (targeted analysis) | 25 ppb | Targeted analysis; polymeric PFAS excluded. |
| Sum of PFAS | 250 ppb | Sum of targeted analyses; may include degradation products of precursor compounds where applicable; polymeric PFAS excluded |
| Total fluorine | 50 ppm | Includes polymeric PFAS. |
Further reading
- The practical application of this regulation raises numerous questions. The German Association for Plastics Packaging and Films (Industrievereinigung Kunststoffverpackungen e. V.) has prepared an Information and proposal for implementing the requirements for PFAS limit values in the PPWR (as of March 13, 2026), which includes a proposed testing strategy. A procedure is also recommended for PFAS as NIAS (non-intentionally added substances) (see p. 11).
- In addition, the European Food Safety Authority (EFSA) published the report of its online workshop held on 17 November 2025, titled Workshop on the Latest Advancements of PFAS Risk Assessment (Event Report published on 10 March 2026), which explores recent developments in PFAS risk assessment.
- In March 2026, the European Commission also released a Frequently Asked Questions (FAQ) document addressing the most common questions related to the PPWR.
Practical implications
Implementing the requirements of Article 5 involves three key areas of action:
- Material substitution: Transition to PFAS-free barrier and coating systems.
- Supply chain transparency: Establish Full Material Disclosure (FMD) processes and obtain reliable analytical data from upstream suppliers.
- Compliance management: Prepare legally robust compliance documentation that can withstand regulatory market surveillance.
How we can support you
PFAS laboratory testing & mitigation: our Packaging lab is testing PFAS, total Fluorine and sum of PFAS in all types of food contact materials, and supporting you in identifying sources of PFAS contamination in your supply-chain;
Ensure full compliance with the new PPWR regulation through our expert technical eco-design assessments and packaging recyclability analyses. Our specialists guide your business through volume reduction initiatives and recycled content certifications. We help you meet mandatory EU targets while transforming regulatory compliance into a strategic competitive advantage.
