What is the PPWR PFAS restriction for packaging?

Per- and polyfluoroalkyl substances (PFAS) are a large family of persistent synthetic chemicals widely known as forever chemicals. The European Packaging and Packaging Waste Regulation strictly restricts their presence above specific concentration thresholds in food-contact packaging from 12 August 2026.

For decades, the packaging industry relied heavily on these highly resilient chemicals to create greaseproof burger wrappers, waterproof paper bowls, and stain-resistant food containers. Because these synthetic compounds repel both oil and water effectively, they became the default engineering choice for merchants looking to serve hot, greasy, or liquid-heavy foods without the packaging disintegrating in the customer's hands. However, this same chemical resilience means they do not break down in the natural environment, leading to severe bioaccumulation and the contamination of water supplies worldwide.

The new European legal framework forcefully removes these materials from the food packaging supply chain. Rather than relying on voluntary industry phase-outs or fragmented national bans, the law imposes a strict, harmonised restriction across all member states. For merchants and importers, this forces an immediate redesign of any paper, cardboard, or plastic packaging designed to touch food. Failing to audit suppliers and remove these chemicals will result in packaging being illegally placed on the market, risking immediate product recalls, administrative penalties, and blocked border shipments.

What the PFAS restriction actually means

The restriction targets thousands of synthetic chemicals that share a specific molecular structure, generally defined as containing at least one fully fluorinated methyl or methylene carbon atom. Because all PFAS within the scope of the regulation are either very persistent themselves or degrade into very persistent environmental contaminants, the law treats them as a severe environmental and human health hazard. When looking at human health endpoints following long-term exposure, a large number of these chemicals are formally classified for carcinogenicity, mutagenicity, and reproductive toxicity.

Under the Packaging and Packaging Waste Regulation (PPWR), regulators are capping the allowable presence of these chemicals at minute parts-per-billion and parts-per-million levels to effectively ban their intentional use. If a packaging unit is intended to be brought into contact with food, or is already in contact with food, it cannot be legally placed on the European market if it exceeds these strict thresholds.

"From 12 August 2026, food-contact packaging shall not be placed on the market if it contains per- and polyfluorinated alkyl substances (PFAS) in a concentration equal to or above the following limit values..."

Crucially, a business cannot simply claim their packaging is safe; they must prove it. Compliance with these chemical limits must be formally demonstrated within the technical documentation required by Annex VII of the regulation.

Does this apply to me?

If you manufacture, import, or use packaging that touches food in the European Union, this restriction applies directly to your operations. The scope of "food-contact packaging" broadly covers any material intended to come into contact with food under general EU food legislation. This includes fast-food containers, bakery bags, pizza boxes, microwave popcorn bags, and rigid plastic food trays.

The legal responsibility to ensure the packaging meets these chemical limits falls on the manufacturer or the importer placing the item on the market. If you import pre-packaged food from Asia or North America, or import empty food packaging to fill locally, you are legally responsible for demanding laboratory test results from your suppliers to prove the packaging does not exceed the limit values.

There are absolutely no exceptions regarding packaging containing recycled material. Even if the restricted chemicals enter your packaging unintentionally via a contaminated recycled paper pulp stream, the final packaging unit must still test below the legal concentration limits.

Thresholds and compliance deadlines

The new rules impose strict limits that dictate the future of food-contact materials. Notably, the European Commission has explicitly stated that there is no transitional period for the exhaustion of existing packaging stocks.

Common misconceptions about the PFAS restriction

It only applies to liquid food packaging. This is incorrect. The restriction applies to all food-contact packaging, regardless of whether it holds a liquid, a dry solid, or a greasy item. Fast-food wrappers, dry bakery bags, and cardboard takeaway boxes are all heavily scrutinised because paper and board are frequently treated with these chemicals to prevent oil and grease stains.

I can sell my old stock after the deadline. There is no transitional period for exhausting existing packaging inventory. Any food-contact packaging placed on the European market after 12 August 2026 must comply with the strict chemical limits, even if it was manufactured months or years prior. Only packaging that was already placed on the market before that exact date is allowed to remain in circulation.

The limits only apply to intentionally added chemicals. The regulation sets absolute concentration limits regardless of how the chemicals entered the material. Even if you do not intentionally add forever chemicals to your packaging, you will be penalised if they are present as contaminants - such as through the use of polluted recycled paper pulp - at levels exceeding 50 parts per million.

My standard material safety data sheet (MSDS) is enough proof. A basic safety sheet from your supplier will not satisfy market surveillance authorities. You must provide specific proof of the quantity of fluorine measured as content and formally document the compliance within the strict Annex VII technical documentation required by the regulation.

5 examples of the PFAS restriction in practice

1. Reformulating microwave popcorn bags A snack brand must replace the interior grease-resistant lining of its paper popcorn bags. The manufacturer switches to an alternative mechanical paper densification technique to repel the hot oil, ensuring the bag tests well below the 250 ppb sum limit for targeted analysis.

2. Auditing fast-food wrappers A burger franchise operating across Europe demands new laboratory testing from its paper supplier. They must ensure the total fluorine content in their printed wrapping paper does not exceed the 50 mg/kg trigger threshold before drawing up their technical documentation.

3. Rejecting non-compliant imported stock An importer of Asian food products halts a shipment of ready-to-eat noodle bowls because the supplier cannot provide chemical test results. Placing those bowls on the market after August 2026 without Annex VII documentation would be illegal.

4. Upgrading recycled paper streams A manufacturer of moulded fibre egg cartons sources recycled paper pulp but discovers it is heavily contaminated with forever chemicals from old fast-food waste. They must switch to a cleaner pulp source to ensure the final cartons meet the strict European concentration limits.

5. Discontinuing old takeaway boxes A restaurant wholesaler discovers their warehouse contains thousands of untreated cardboard pizza boxes that were manufactured using restricted coatings. Because there is no exhaustion of stocks provision, they must either sell them before the August 2026 deadline or destroy the remaining inventory.

Terms related to the PFAS restriction

Frequently asked questions

Why are these chemicals banned in packaging?

Forever chemicals are heavily restricted because they represent a severe environmental and human health hazard. They are incredibly persistent in the environment and do not break down naturally. Prolonged human exposure to certain chemicals within this family has been linked to severe health issues, including carcinogenicity, mutagenicity, and reproductive toxicity.

Does this rule apply to non-food packaging?

The specific restriction outlined in Article 5(5) of the Packaging and Packaging Waste Regulation applies exclusively to food-contact packaging. However, merchants should be aware that other broad European chemical regulations, such as REACH, may place separate restrictions on the use of these substances in general consumer goods and non-food packaging.

How do I prove my packaging is compliant?

To prove your packaging does not exceed the restricted thresholds, you must rely on targeted laboratory analysis. If the total fluorine content exceeds 50 mg/kg, you must secure proof of the specific quantity of fluorine measured as content. This evidence must then be formally recorded and maintained in your Annex VII technical documentation.

Are there exemptions for recycled materials?

No. There are no exemptions regarding packaging containing recycled material. If you use recycled paper or plastics to manufacture food-contact packaging, you must still ensure that the final material meets the strict parts-per-billion or parts-per-million thresholds. If your recycled feedstocks are contaminated, you cannot use them for food applications.

What happens if I miss the deadline?

Food-contact packaging cannot be legally placed on the European market after 12 August 2026 if it exceeds the limit values. If you fail to comply, market surveillance authorities have the power to block your shipments at customs, issue substantial administrative fines, and order immediate product recalls across the continent.

Sources:

• Packaging and Packaging Waste Regulation (EU) 2025/40
• Commission Notice – Guidance document for Regulation (EU) 2025/40 on packaging