PFAS in Food Packaging: PPWR Limits and Evidence

From 12 August 2026, food-contact packaging cannot be placed on the EU market at or above any of the PPWR's three PFAS limits: 25 ppb for one targeted PFAS, 250 ppb for their targeted sum, or 50 ppm including polymeric PFAS. The thresholds sit in Article 5(5) of Regulation (EU) 2025/40.

Key takeaways

• The PPWR uses three separate PFAS thresholds, and meeting only one does not override the others.
• The 25 ppb and 250 ppb limits exclude polymeric PFAS; the 50 ppm limit includes them.
• Total fluorine above 50 mg/kg triggers an evidence requirement, not an automatic conclusion that all fluorine is PFAS.
• The packaging manufacturer's technical file should connect supplier specifications, assessment methods and test evidence to the exact packaging identity.

Which food-contact packaging is covered?

Article 5(5) covers packaging intended to come into contact with food as defined by Regulation (EC) No 1935/2004. The restriction applies when that packaging is placed on the EU market from 12 August 2026, to the extent the PFAS use is not already prohibited by another Union legal act.

The scope follows the packaging's intended food-contact function, not a shortlist of materials. Paper, board, moulded fibre, plastic, coatings, inks, adhesives and multilayer structures can all require attention when they form part of food-contact packaging.

The practical first step is therefore an inventory, not an assumption about which material is "PFAS-free". Identify every food-contact component, its supplier, its formulation or specification reference, and the evidence attached to the finished packaging configuration.

What are the PPWR PFAS concentration limits?

The PPWR restricts food-contact packaging when any of three concentration limits is met or exceeded. Each threshold has a different analytical scope.

Food-contact packaging has to remain below all three applicable Article 5(5) limits from 12 August 2026.

The official PPWR substance limits use parts per billion for the targeted thresholds and parts per million for the broader threshold. Keep the original unit beside every result so a conversion does not hide which legal test the evidence addresses.

These PFAS rules sit alongside the PPWR's existing heavy-metal restriction. The guide to PPWR restricted substances and heavy metals covers that separate part of Article 5.

How should total fluorine results be handled?

Total fluorine is a screening signal, but it does not identify whether the fluorine comes from PFAS. Article 5(5)(c) addresses this distinction directly.

If total fluorine exceeds 50 mg/kg, the manufacturer, importer or downstream user must provide proof, on request, of the fluorine content measured as either PFAS or non-PFAS. The purpose is to give the packaging manufacturer the evidence needed for the technical documentation.

That wording matters. A total-fluorine result above 50 mg/kg should not be rewritten as an automatic PFAS failure without the follow-up evidence required to distinguish the source. Equally, a supplier statement with no method, sample identity or result cannot demonstrate which threshold was assessed.

What evidence belongs in the technical file?

The packaging manufacturer's technical file should make it possible to assess compliance with Article 5 for the specific packaging placed on the market. Annex VII uses internal production control and requires evidence that connects the design, materials and assessment results.

A practical PFAS evidence set should contain:

1. Packaging identity. Product name, component list, drawing or specification revision, intended food-contact use and supplier references.
2. Material information. Specifications for coatings, barriers, inks, adhesives and other food-contact components.
3. Supplier evidence. Declarations, formulation information and supporting documents tied to the exact supplied material.
4. Assessment record. Which Article 5(5) thresholds were assessed, the analytical scope and why the selected evidence is appropriate.
5. Test reports where needed. Sample identity, laboratory, method, detection limits, units, results and date.
6. Conclusion. A clear link from the evidence to the packaging manufacturer's conformity assessment and EU Declaration of Conformity.

Article 16 requires suppliers of packaging or packaging materials to provide the manufacturer with the information and documentation necessary to demonstrate conformity. The workflow in collecting PPWR technical documentation from suppliers turns that obligation into a request list.

Who is responsible across the supply chain?

The packaging manufacturer remains responsible for the conformity assessment, technical documentation and EU Declaration of Conformity when placing packaging on the market under its name or trade mark. A supplier test report supports that process but does not replace the manufacturer's conclusion.

An importer must verify that the manufacturer carried out the conformity assessment and compiled the technical documentation before placing packaging from outside the EU on the market. A distributor must act with due care and verify the applicable identification and documentation requirements before making the packaging available.

The merchant's exact role depends on who designed, specified, branded or imported the packaging. The PPWR technical-documentation guide explains how the Annex VII file fits together, while the merchant remains the signatory where the merchant is the legal manufacturer.

What should you do before 12 August 2026?

Businesses should triage food-contact packaging by evidence risk rather than testing every item indiscriminately.

1. Map every food-contact packaging component and its supplier.
2. Ask suppliers which of the three Article 5(5) thresholds their evidence addresses.
3. Check that declarations and reports identify the same material revision you actually buy.
4. Escalate missing, ambiguous or high-risk evidence for technical review and proportionate testing.
5. Store the result with the packaging identity, assessment and Declaration of Conformity.
6. Re-open the assessment whenever a coating, adhesive, ink, supplier or manufacturing process changes.

The Commission must evaluate by 12 August 2030 whether Article 5(5) should be amended or repealed to avoid overlap with restrictions under EU food-contact, REACH or persistent-organic-pollutant rules. Treat the file as maintained evidence, not a certificate gathered once and forgotten.

Gramta produces and stores the PPWR technical file and Declaration of Conformity from the packaging evidence you provide. The merchant remains the signatory. Get started with Gramta to keep specifications, evidence and country-by-country EPR reporting connected in one packaging record.

Sources:

• Regulation (EU) 2025/40, Article 5 and Annex VII