PFAS Ban in Food Packaging: EU Rules for 2026

The PPWR PFAS Restriction: What It Actually Says

On August 12, 2026, a strict restriction on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging takes effect across the European Union. The restriction is found in Article 5, paragraph 5 of Regulation (EU) 2025/40 -- the EU Packaging and Packaging Waste Regulation, commonly known as the PPWR.

A critical distinction first: this restriction applies to food-contact packaging only. It does not cover all packaging. If your packaging never touches food, beverages, or consumable products, this specific provision does not apply to you. Other PPWR requirements still do, but the PFAS limits are scoped exclusively to packaging intended for food contact.

The regulation defines PFAS broadly, aligning with the OECD definition: any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom. This is not a narrow list of a few well-known chemicals. It covers thousands of substances, including PTFE (the material in non-stick coatings) and many fluoropolymers used in grease-resistant packaging treatments.

The Three-Tier Concentration Limits

Article 5(5) establishes three separate concentration limits. All three must be met simultaneously. Failing any single tier means the packaging is non-compliant.

Tier	Limit	What It Measures
(a)	25 ppb (25 microg/kg)	Any individual PFAS substance, excluding polymeric PFAS
(b)	250 ppb (250 microg/kg)	Sum of all PFAS substances, excluding polymeric PFAS
(c)	50 ppm (50 mg/kg)	Total PFAS including polymeric PFAS (total fluorine proxy)

Think of it as a funnel. Tier (c) catches the broadest category -- total fluorine content including polymeric forms like PTFE. If your packaging contains PTFE-based coatings, it will likely fail tier (c) even if individual non-polymeric PFAS levels are low. Tiers (a) and (b) then zero in on non-polymeric PFAS at much lower thresholds.

The practical effect: packaging with any intentional fluorochemical treatment will almost certainly exceed these limits. Even unintentional contamination from recycled content or manufacturing environments can push results above 25 ppb for individual substances.

No Grandfathering -- The Deadline Is Absolute

There is no transitional period for the PFAS restriction. The draft Commission Notice on PPWR implementation states explicitly: "The PPWR does not foresee a transitional period for these restrictions."

This means packaging placed on the EU market after August 12, 2026 must comply, regardless of when it was manufactured. If you have existing inventory of PFAS-containing food-contact packaging, you cannot sell it into the EU after that date. Manufacturing date is irrelevant; market placement date is what counts.

This is a hard cutoff. Businesses that wait until mid-2026 to address their packaging risk having non-compliant stock they cannot legally sell in the EU.

Which Products Are Affected?

The restriction targets food-contact packaging where PFAS has historically been used for grease resistance, moisture barriers, or non-stick properties. Common examples include:

Takeaway containers -- moulded fibre bowls, clamshells, and trays
Bakery bags -- grease-resistant paper bags for pastries and bread
Grease-resistant wraps -- deli paper, burger wraps, sandwich wraps
Coated cardboard -- pizza boxes, french fry cartons, popcorn buckets
Microwave-safe containers -- coated paperboard trays
Moulded fibre trays -- egg cartons, produce trays with food contact
Pet food packaging -- bags and pouches with grease barriers

If your product is a dry good shipped in a simple cardboard box with no special coating, you are likely fine. The concern arises whenever the packaging material has been treated to resist grease, oil, or moisture -- that treatment is often PFAS-based.

How Do I Know If My Packaging Contains PFAS?

This is the question every food business is asking. Unfortunately, supplier declarations alone are not sufficient proof of compliance. Many suppliers are unaware of PFAS content in their materials, particularly when using recycled inputs or purchasing from sub-suppliers.

Step 1: Ask your supplier directly

Request a written statement on whether intentionally added PFAS or fluorochemical treatments are used. Ask specifically about grease-resistance treatments, moisture barriers, and any fluoropolymer coatings. A credible supplier will reference their raw material specifications and testing data.

Step 2: Check for fluorochemical indicators

Look for terms like "grease-proof," "oil-resistant," "C6 treatment," "fluorochemical finish," or brand names of fluoropolymer coatings in your packaging specifications. These are strong indicators of PFAS content.

Step 3: Get your packaging tested

Testing is the only way to confirm compliance with certainty. The draft Commission Notice outlines a tiered testing approach:

Screening (Total Fluorine): A total organic fluorine (TOF) test measures overall fluorine content. If the result is below 50 ppm (tier c), the packaging passes the broadest check. This is the fastest and cheapest test.

Detailed Analysis (Pyrolysis-GC/MS): If screening shows elevated fluorine, pyrolysis-GC/MS distinguishes between organic and inorganic fluorine sources. This helps determine whether the fluorine comes from PFAS or from non-PFAS sources like mineral contamination.

Targeted Testing (TOP Assay + LC-MS/MS): The most detailed tier. A total oxidisable precursor (TOP) assay combined with targeted LC-MS/MS analysis checks compliance with the 25 ppb individual and 250 ppb sum limits. This identifies specific PFAS compounds.

Note: no CEN harmonised testing standards exist yet for these PPWR-specific limits. The testing framework described above comes from the draft Commission Notice and follows established analytical methods, but formal standardisation is still in progress.

What Does Testing Cost?

Laboratory testing is not free, but it is far cheaper than the consequences of non-compliance. Based on current list prices from accredited laboratories (Measurlabs reference pricing):

Test	Approximate Cost
Heavy metals screening	EUR 158--198 per sample
Total organic fluorine (TOF) screening	EUR 167 per sample
Targeted PFAS analysis (165 compounds)	EUR 365 per sample
Service/handling fee	EUR 97 per order
Full food-contact testing bundle	EUR 790--860 total

For most businesses, the practical approach is to start with TOF screening at EUR 167 per sample. If your packaging passes that threshold (below 50 ppm total fluorine), you have strong evidence of compliance without needing the more expensive targeted analysis.

If you have multiple packaging types, prioritise testing on the materials most likely to contain PFAS: anything with grease-resistant coatings, moulded fibre products, and coated paperboard.

Interaction With Other EU Regulations

The PPWR PFAS restriction exists alongside, not instead of, other EU food-contact regulations. Article 5(5) operates "without prejudice to" Regulation (EC) No 1935/2004 (the framework regulation on food-contact materials) and Regulation (EU) No 10/2011 (specific rules for plastic food-contact materials).

This means food-contact packaging must meet both the PPWR PFAS limits and any existing food-contact material requirements. The PPWR adds a layer; it does not replace existing obligations.

The restriction is also separate from the ongoing REACH Annex XVII process, which is considering a much broader PFAS restriction across all uses. The PPWR restriction is sector-specific (food-contact packaging) and arrives years ahead of any potential REACH universal PFAS ban. A 2030 review clause in the PPWR will assess potential overlaps between these regulatory frameworks.

What Should You Do Now?

With less than five months until the August 12, 2026 deadline, the time for action is now:

Audit your packaging inventory -- identify every food-contact packaging component
Contact your suppliers -- request PFAS declarations and material safety data
Prioritise testing -- start with TOF screening on high-risk materials (grease-resistant, coated, moulded fibre)
Source alternatives -- if testing reveals PFAS, switch to silicone-based, wax-based, or aqueous barrier coatings
Clear old stock -- sell through any PFAS-containing packaging before August 12, 2026
Document everything -- keep test reports, supplier declarations, and switching records for your compliance file

The PFAS restriction is one of the earliest PPWR obligations to bite, and it has no grace period. Businesses that act now will have compliant packaging in place. Those that delay risk pulling products from shelves.

Need help assessing your food-contact packaging for PPWR compliance? Create a free account to run your packaging through our compliance checker and get a clear picture of what needs to change before August 2026.