PFAS are increasingly under scrutiny due to their persistence in the environment and potential impact on human health. These substances have been used in certain food-contact packaging materials, particularly where resistance to grease and moisture is required. With the introduction of new requirements under the EU Packaging and Packaging Waste Regulation (PPWR), food packaging manufacturers, importers and distributors need to pay closer attention to the composition of their materials. The key question is no longer just what the packaging is made of, but whether its compliance can be properly demonstrated.
What are PFAS and where are they used in food packaging?
PFAS (per- and polyfluoroalkyl substances) are a large group of synthetic chemicals valued for their resistance to water, oil, grease and high temperatures. Due to these properties, they have been used in various industrial applications, including certain materials and coatings intended for food-contact packaging.
In the packaging industry, PFAS may be found in some paper and cardboard products treated to provide grease resistance. Typical examples include pizza boxes, burger and sandwich wraps, bakery bags and microwave popcorn bags.
It is important to note that not all paper, cardboard or plastic packaging contains PFAS. Their presence depends on the material composition, coatings and treatments used during manufacturing.
What does the new EU regulation require?
Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) introduces restrictions on PFAS in food-contact packaging. Under Article 5(5), packaging intended to come into contact with food must not be placed on the EU market if it contains PFAS at or above the following concentration limits:
25 ppb for any individual PFAS, as measured by targeted analysis, excluding polymeric PFAS.
250 ppb for the sum of PFAS measured as the sum of targeted analyses, with the possibility of including PFAS resulting from precursor degradation.
50 ppm for total PFAS, including polymeric PFAS.
Where the total fluorine concentration exceeds 50 mg/kg, manufacturers, importers or downstream users may be required to provide evidence demonstrating that the measured fluorine originates from PFAS or non-PFAS substances.
These restrictions apply from 12 August 2026. They do not represent a general ban on all PFAS or all types of packaging. The requirements specifically concern packaging intended to come into contact with food and its compliance with the prescribed concentration limits.
How can PFAS be detected in packaging?
Verifying PFAS compliance can be more complex than checking a standard material specification. There is no single harmonised testing method that covers every type of food-contact packaging and every PFAS compound.
The European Commission's guidance describes a staged approach to testing. Initial screening can be performed by measuring total fluorine. If the result exceeds 50 mg/kg, further analysis may be needed to determine whether the fluorine originates from PFAS or other substances.
Depending on the material and the purpose of the analysis, additional methods may include targeted PFAS analysis and techniques such as Pyrolysis-GC/MS or the Total Oxidisable Precursor (TOP) assay.
A total fluorine result is therefore useful as an initial screening tool, but it does not automatically establish whether packaging complies with the specific PFAS limits.
What documentation should you request from your packaging supplier?
For manufacturers and distributors using food-contact packaging, supplier documentation is an important part of demonstrating compliance.
A Declaration of Compliance or a separate supplier statement should clarify whether PFAS are intentionally added during the production of the packaging or any of its components. It is also useful to obtain detailed information about the material structure, including the base material, coatings, surface treatments and barrier layers.
Where available, laboratory test reports should specify the analytical methods used, the substances tested and the measured results. Documentation should relate to the actual packaging material or finished packaging being supplied, rather than relying solely on a statement concerning one individual component.
One distinction is particularly important: a statement that no PFAS are intentionally added does not, by itself, prove that the packaging meets the concentration limits set by the regulation.
For this reason, manufacturers and importers should establish clear documentation requirements with their suppliers and ensure that the information covers the complete packaging structure.
What alternatives are available?
The packaging industry is developing alternative solutions to replace PFAS-based grease and moisture barriers. These include water-based barrier coatings, alternative polymer coatings and other material structures designed to provide the required functional properties without the intentional use of PFAS.
However, replacing one coating with another is not simply a matter of choosing a PFAS-free alternative. The packaging must still meet food-contact safety requirements and provide the necessary resistance to grease, moisture and other external factors. Its performance, recyclability and compatibility with existing production and packaging lines must also be considered.
The most suitable solution will depend on the type of food product, packaging application and technical requirements of the manufacturer.