PPWR PFAS limits for food-contact packaging
This is one of the few PPWR requirements that bites immediately on 12 August 2026 — and the evidence for it usually sits with your suppliers, not with you.
Free PPWR Check60 seconds. Find out whether this packaging should be reviewed.The restriction
Regulation (EU) 2025/40 restricts per- and polyfluoroalkyl substances (PFAS) in food-contact packaging placed on the EU market from 12 August 2026, where PFAS are present above the concentration thresholds set out in the Regulation. The thresholds are expressed for PFAS measured as total fluorine, as the sum of targeted PFAS, and for individual PFAS, at levels intended to exclude intentional use rather than trace contamination.
Why it catches people out
- Grease-resistant paper and board. Fluorochemical treatments have been common in fast-food wraps, bakery liners, moulded fibre bowls and pet-food bags.
- Coatings and barrier layers. The PFAS may be in a coating or additive your converter buys, two tiers up the supply chain from you.
- Non-stick processing aids. Substances used in production can carry through into the finished packaging.
- Vague declarations. "PFAS-free" statements without a threshold, a test method or a scope are not usable evidence.
What usable evidence looks like
- A component-level list of every material in contact with, or capable of migrating into, the food.
- Supplier declarations that name the thresholds and state the basis: formulation knowledge, analytical testing, or both.
- Test reports where declarations are not sufficient — typically total fluorine screening, followed by targeted PFAS analysis if fluorine is detected.
- Traceability from the report to the exact material grade and the packaging configuration in the Annex VII technical documentation.
Sequence we recommend
Map components → request specific supplier declarations with the thresholds stated → screen the uncertain materials → test only where screening indicates → record everything in the technical file so it supports the Declaration of Conformity. Blanket testing of every component is expensive and usually unnecessary.
Testing lead times and supply-chain response times are the binding constraint here, not the paperwork. Starting late is the main risk.
This page summarises the Regulation for general information and is not legal advice; the Regulation text and any acts adopted under it are authoritative.
Last reviewed: 11 August 2026. Written and maintained by the PPWRDeclaration.com editorial team. This page is general information about Regulation (EU) 2025/40 and is not legal advice.
Why this matters
What happens if the documentation isn't there
The packaging can be restricted
Packaging without valid technical documentation is treated as non-compliant. Market surveillance authorities can require corrective action, restrict sale, or withdraw it from the market.
Penalties apply per Member State
Each Member State sets its own penalties for non-compliance, and they apply where the packaging is placed on the market — not where your business sits.
Buyers block you first
Retailers, distributors and importers increasingly ask for the Declaration and supporting evidence before onboarding. No file usually means no listing.
Late evidence costs more
Supplier declarations and lab testing have long lead times. Discovering a gap close to a deadline forces rushed testing or packaging redesign.