PFAS in food packaging under the PPWR: limits, testing, evidence

Since 12 August 2026, food-contact packaging placed on the EU market has had to stay below the PFAS limits in Article 5(5) of Regulation (EU) 2025/40 (the PPWR). The Commission’s guidance says there is no stock-exhaustion period for PFAS-containing food-contact packaging, and as of 15 November 2026 the application date has not been postponed.

This explainer covers the three numerical limits, the total fluorine screen, what “placed on the market” means for your inventory, and a testing and documentation routine. Legal points come from the Regulation and Commission documents. Several of the practical readings below come from testing laboratories, trade bodies and compliance software firms, which sell services around PFAS; they are named where used.

The three PFAS limits in Article 5(5)

The limits apply to food-contact packaging, meaning packaging intended to touch food or already in contact with it for that purpose. From 12 August 2026 such packaging may not be placed on the EU market if it contains PFAS at or above the limit values, unless another EU act already bans the relevant concentration. The thresholds are expressed as “at or above”: the Food and Drink Federation’s guidance reads them as 25 ppb for any individual PFAS, 250 ppb for the sum of targeted PFAS and 50 ppm for total PFAS including polymeric PFAS.

Limit	Applies to	Polymeric PFAS	How it is measured
25 ppb	Any single PFAS	Excluded	Targeted PFAS analysis
250 ppb	Sum of PFAS	Excluded	Sum of targeted analysis, with prior degradation of precursors where applicable
50 ppm	PFAS in total	Included	Total fluorine used as a first screen; see below

The treatment of polymeric PFAS explains why one method is not enough. Polymeric PFAS are left out of the first two quantifications but counted in the 50 ppm limit. Targeted methods look for named substances, so a fluoropolymer coating can pass a targeted test and still count towards the 50 ppm limit.

Our calculation: 50 ppm equals 50 mg/kg, or 50,000 µg/kg, which is 50,000 ppb. Divided by the 25 ppb single-substance limit, 50,000 ÷ 25 = 2,000. The total limit is 2,000 times the single-substance limit in numerical terms, which is why the two cover different risks: trace migrating substances on one side, bulk fluorinated coatings on the other.

Total fluorine: a screen and a documentation trigger

Article 5(5) also contains a fluorine rule that is often misread. Where total fluorine exceeds 50 mg/kg, the manufacturer, importer or downstream user of the chemical must, on request, give evidence of how much of that fluorine comes from PFAS and how much from non-PFAS substances. That evidence feeds the packaging manufacturer’s technical documentation.

Total fluorine and total PFAS are different quantities. Thermo Fisher’s testing blog makes the point that total fluorine is not the same thing as total PFAS. Inorganic fluoride salts, for example, add to the fluorine reading without being PFAS. A result above 50 mg/kg therefore triggers a follow-up question and does not, by itself, show a breach.

Testing: no harmonised method yet

The Commission accepts that testing is unsettled. Its FAQ notes that no harmonised EU test method exists for PFAS in food packaging, that it is working towards a common approach among national market surveillance authorities, and that many laboratories offer total fluorine and total organic fluorine analyses. The Commission’s guidance recommends a stepped approach for that reason, and the Commission states that its guidance and FAQs do not replace, add to or amend the provisions of the PPWR. Treat the steps as a recommended route and not as a legal safe harbour.

Step	Test	Result	Next action
1	Total fluorine (TF)	Below 50 mg/kg	The sample may be considered compliant; record result and sampling basis
2	Separate organic from inorganic fluorine, for example by py-GC/MS	Total organic fluorine below 50 ppm	Considered compliant, no further testing
3	Targeted PFAS analysis	Each PFAS below 25 ppb; sum below 250 ppb	Compliant on the numerical limits; keep the report

Cepi, the paper industry federation, published a PFAS guide for the PPWR on 28 July 2026 that follows the same three steps. It cautions that organic fluorine above 50 ppm is a strong indicator but does not by itself show that PFAS exceed the Article 5(5) limit. Step 3 is where a borderline result gets resolved.

One compliance vendor, Sunhat, advises that test reports should state a limit of quantification below the 25 ppb threshold. A method that cannot see 25 ppb cannot demonstrate that you are under it, so ask the laboratory for the quantification limit before you commission work.

Stock and the date of placing on the market

The Commission’s guidance annex addresses stock directly: for packaging containing PFAS produced before 12 August 2026, the PPWR does not foresee a transitional period for exhausting stocks. At first reading this seems to conflict with another statement. The Food and Drink Federation summarises the Commission position as: packaging placed on the market before that date may remain on the market, with no general stock-exhaustion period.

The two fit together once you apply the legal trigger, which is placing on the market and not manufacture. The FDF notes that the Commission treats empty or filled food-contact packaging as placed on the market through an offer or agreement transferring ownership, possession or another property right once manufacture is complete. A pallet of coated trays sitting in your warehouse and not yet supplied is therefore at risk, while trays already supplied to a customer before the date are not.

Filled sales packaging needs separate thought. One consultancy, Chemicalcell, reads the guidance as treating sales packaging as placed on the market when filled, where final processing such as sealing can influence compliance. That is a secondary reading; check the guidance text or take legal advice before releasing disputed stock.

Who must do what

The PPWR spreads the evidence burden along the chain. Manufacturers carry out the conformity assessment, importers ensure one has been done, technical documentation is kept for five years (ten for reusable packaging), and the manufacturer issues the EU declaration of conformity. Distributors verify that packaging complies and that manufacturers and importers have met their duties.

Role	PFAS-related task
Packaging manufacturer	Assess conformity, compile technical documentation, issue the EU declaration of conformity
Importer	Ensure the manufacturer has done the assessment; hold the documentation
Chemical supplier	Provide fluorine evidence on request when total fluorine exceeds 50 mg/kg
Distributor and retailer	Verify the packaging and its paperwork before supplying it

The Commission’s guidance annex is dated 30 March 2026 (reference C(2026) 2151). Some secondary sources, such as REACH24H, date a final version to June 2026; we could not confirm a separate June text on the Commission’s site, so check the Commission implementation page, which lists the March 2026 guidelines and the August 2026 FAQ, for the current version.

What the PFAS limits do not cover

The numerical PFAS limits are specific to food packaging. The Regulation sets no general concentration thresholds for substances of concern, apart from certain heavy metals and PFAS, and the PFAS maximums apply to food packaging only. All packaging still falls under the duty to minimise substances of concern, and the minimisation obligation and the heavy-metal limit apply to all packaging from 12 August 2026. A cosmetics tube or a transport carton needs substance documentation, but not a PFAS threshold test under Article 5(5).

What to do now

List every food-contact item. Include liners, coatings, inks, adhesives and barrier layers on trays, wraps, cups, sleeves and bags. Mark which ones were supplied before 12 August 2026 and which were not.
Ask suppliers in writing whether PFAS or fluoropolymers are intentionally used anywhere in the structure, and for total fluorine results with the method, sample and quantification limit stated. A “PFAS-free” statement alone is thin evidence.
Run total fluorine first. Move to organic fluorine and targeted analysis only for items above 50 mg/kg, and log the sampling basis for each result.
Quarantine doubtful stock. Decide per lot whether it was placed on the market before the date; do not ship uncertain lots until the position is documented.
Put the evidence in the technical documentation and make sure your declaration of conformity matches it. Set a retention period of five years as a minimum.
Agree a request route with chemical suppliers for the fluorine attribution evidence, so a request is answered in days and not weeks.
Brief purchasing. Contracts for coated paper, moulded fibre and plastics should carry a clause requiring notice of any formulation change involving fluorinated substances.
Check tools by what they do. Packaging Insights reports that FoodChain ID will demonstrate its PPWR compliance software, which organises supplier information by role, in a free webinar on 17 November 2026. The company sells the product, so treat the session as a demonstration and compare it with your own data needs.

This article is information, not legal advice. Where a decision depends on the wording of Article 5, read the official text or take legal advice for your product.

Sources

Header image: illustration, AI-generated.