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PFAS in food-contact packaging — the PPWR ban

From 12 August 2026, PPWR bans PFAS in packaging that comes into contact with food. For sellers of food, food supplements and prepared meals it is one of the few obligations that bites on the application date, with no transition period. It is also one of the easiest to breach unknowingly, because PFAS most often hides in exactly the "eco-looking" paper packaging.

What PFAS is, and why it's in packaging

PFAS (per- and polyfluorinated alkyl substances, "PFAS" in the regulation) are a group of thousands of synthetic "forever chemicals". In packaging they are used for grease, oil and water resistance. This is why they end up in food packaging: paper and board takeaway containers, fast-food boxes, wrappers, popcorn bags, greaseproof paper, moulded-fibre (bagasse) plates and bowls, and paper straws. Paper, board and moulded fibre marketed as "grease/water-resistant" or "compostable" are the highest-risk category; plastic and glass are generally low-risk, but not automatically zero.

Which packaging is covered

The ban applies to food-contact packaging: packaging intended for direct contact with food, including food supplements, which count as food under EU law.

An important boundary: cosmetics packaging is not covered by this PPWR ban. Cosmetics fall under a broader category ("contact-sensitive packaging") defined separately in the regulation, which triggers other rules (such as recycled-content requirements) but not this PFAS restriction. PFAS in cosmetics is governed by other legislation, not PPWR.

Limit values (Article 5(5))

Food-contact packaging may not be placed on the market if it contains PFAS at or above these values:

  • 25 ppb for any single PFAS (targeted analysis; polymeric PFAS excluded from quantification),
  • 250 ppb for the sum of PFAS (targeted analysis, with degradation of precursors where applicable),
  • 50 ppm (50 mg/kg) for all PFAS, including polymeric.

There is also a trigger: if total fluorine exceeds 50 mg/kg, the supplier must, on request, document how much of it is PFAS and how much comes from other sources of fluorine, so that you can compile the technical documentation (Annex VII). (ppb = µg/kg, ppm = mg/kg; 1 ppm = 1,000 ppb.)

No transition period

The 12 August 2026 date for PFAS is stated inside Article 5 itself and confirmed by Article 71. There is no grace period and no separate later date for this ban: from the application date, food packaging that exceeds the limit values may not be placed on the EU market. The regulation provides no specific sell-through window for existing stock, so it is worth checking risky stock in good time.

How to check your packaging

PFAS is invisible. It is proven by testing and supplier documentation. In practice:

  1. Identify which of your packaging comes into direct contact with food (delivery, prepared meals, bakery and greasy products, food supplements).
  2. Ask suppliers for a declaration that the packaging meets the Article 5 PFAS limits.
  3. Request a test report: total (organic) fluorine is usually screened first, and if it exceeds 50 mg/kg, targeted PFAS analysis is run against the 25 ppb and 250 ppb limits.
  4. Keep all of it in the technical documentation (Annex VII) alongside the EU Declaration of Conformity.

If you import packaging or packaged goods from outside the EU, request this documentation upstream from your suppliers. See the guide Importing packaging from China? Your PPWR obligations.

How it fits the rest of PPWR

The PFAS restriction is one of the Article 5 substance requirements; alongside it, the heavy-metals limit and the EU Declaration of Conformity obligation apply from the same date. For the full picture see the guide to Regulation (EU) 2025/40, and for exactly what starts on 12 August 2026 versus later, see What applies from 12 August 2026.

Context note: other EU rules cover PFAS and food-contact materials (e.g. Regulation (EC) No 1935/2004), and a broader PFAS restriction under REACH is still in preparation. This guide covers the PPWR ban.

This guide is informational, helps you prepare documentation, and is not legal advice. For an assessment of your specific packaging, consult a professional.