PFAS limits meet recycled content: what packaging teams must test

A dispute in the UK has put a hard question in front of anyone selling recycled-content food packaging: what happens when a PFAS limit written for safety meets feedstock that carries traces of old coatings? The arguments are British, but the key number in them comes from the EU’s PPWR. Teams selling into the EU need to read the case as an early test of how PFAS limits and recycled content will fit together.

This analysis keeps the documented facts apart from interpretation. Where I interpret, I say so.

What is new

Packaging News reports that the Foodservice Packaging Association (FPA) and the Packaging Federation have raised concerns about PFAS under the Recyclability Assessment Methodology (RAM) 2027, warning that the proposed thresholds could give otherwise recyclable packaging an automatic red rating and raise producers’ pEPR fees. The same report says PackUK is considering further PFAS testing options.

The rule in question is already published. PackUK has issued the RAM framework that applies to recyclability assessments of packaging supplied from 1 January 2027. An item is automatically rated red if it or a component contains more than 1 ppm of PFAS (individual or sum), or if food packaging exceeds 25 ppb for any individual or total PFAS. The previous version had required red only for intentionally added PFAS, and ratings feed into fee modulation.

The industry objection, as Food and Beverage Business reports it, has three parts. The Packaging Federation warns that penalising incidental contamination could encourage manufacturers to choose virgin materials over recycled inputs. It argues that RAM should treat three things separately: whether packaging can be recycled, whether the recovered material is safe and of good quality, and whether the recyclate has commercial value. The FPA, for its part, wants feasible evidence routes, including supplier declarations.

Two limits on the evidence are worth stating. The Packaging Federation cites research showing PFAS can occur in recycled paper and plastic, although the studies do not establish how often UK packaging exceeds the proposed thresholds. And PackUK is examining alternative methods for PFAS testing and verification, with technical discussions between industry and PackUK continuing. I found no report that RAM 2027 has been revised, so the published text stands for now.

Why EU teams should care

Valpak notes that the food packaging threshold in RAM 2027 is derived from the EU’s PPWR, which points to an intent to align the UK and EU. The UK is outside the EU and RAM is a fee-modulation tool, not a market-access rule. The PPWR works differently, as the table shows.

Feature	EU PPWR (Regulation (EU) 2025/40)	UK RAM 2027 (PackUK)
Legal nature	Adopted regulation, applying generally since 12 August 2026	Recyclability methodology for pEPR, for packaging supplied from 1 January 2027
Scope	Food-contact packaging (Article 5(5))	Any item or component, with a stricter threshold for food packaging
Thresholds	25 ppb any single PFAS and 250 ppb sum (targeted analysis, polymeric PFAS excluded); 50 ppm total PFAS including polymeric	Over 1 ppm total PFAS; food packaging over 25 ppb for any individual or total PFAS
Consequence	Packaging at or above a limit cannot be placed on the EU market	Automatic red rating, which affects modulated fees
Recycled material	No exemption, according to Commission guidance	No exemption reported; industry bodies are asking for change

The EU side is documented. The Fieldfisher summary of the regulation gives the Article 5(5) limits as 25 µg/kg for any individual PFAS, 250 µg/kg for the sum (both by targeted analysis, excluding polymeric PFAS) and 50 mg/kg for total PFAS. The Commission’s guidance notice, adopted in June 2026, says there is no exemption for packaging containing recycled materials. The Commission also says, per Packaging Law, that no harmonised EU testing methodology exists for PFAS in food packaging.

In practice this probably means the EU has already answered the question the UK industry is now asking, in the direction the UK bodies fear. A recycled-fibre or recycled-plastic pack that exceeds a limit is out of the market, whatever the source of the PFAS. I’d treat this as an inference, not a quote: the guidance addresses recycled material, but I haven’t seen a Commission statement on how enforcers should treat trace background levels.

Where the exposure sits: fibre first, plastic less so

The PPWR’s PFAS limits apply to food-contact packaging, and the recycled-content minimums apply to plastic. The two sets of rules therefore overlap on recycled plastic in food contact, while recycled paper and board face the PFAS limits without a recycled-content mandate.

For fibre, the evidence of carry-over is the stronger. A Norwegian study analysed 37 PFAS in 13 paper products sampled in 2021, virgin and recycled, including food-contact items. The sum of targeted PFAS ranged from 0.4 to 971 µg/kg. The authors conclude that trace levels in recycled paper and board are unavoidable. The sample is small, and the products were not all food-contact packaging, so it shows possibility, not prevalence. Still, the top of that range sits well above the PPWR’s sum limit for targeted PFAS.

FoodNavigator quotes Biffa’s Wright on the mechanism: once PFAS are in fibre-based packaging they cannot be removed, and fibre and other porous materials are particularly susceptible, while PET, PP, HDPE, glass and metal carry lower contamination risk. That is one industry voice, but it matches the chemistry of porous substrates.

For recycled plastic the picture is less settled. Inline Plastics, a converter, reports that its lab tests on PET with 10 to 100% post-consumer recycled content found no detectable PFAS, while acknowledging that it cannot make sweeping statements about all recycled materials. Other work points the opposite way; an Australian study summarised by the Food Packaging Forum found recycled plastics held double the PFAS levels of virgin plastics. Different resins, sample sets and methods make these results hard to compare. I’d read them as saying the answer depends on the feedstock, so a supplier’s own data matters more than any general claim.

There is also a false-positive problem. A peer-reviewed study on talc in polypropylene found that inorganic contributions to the total fluorine signal can produce false positives that exceed regulatory limits. Mineral-filled plastics may therefore trip the screening step without containing PFAS.

How the Commission expects compliance to be shown

The Commission’s guidance recommends a stepwise approach, which several law firms and labs have summarised. Step 1 is total fluorine: a sample below 50 mg/kg could be considered compliant. Above that, methods such as pyrolysis-GC/MS can show whether the fluorine is organic or inorganic. A third step, direct TOP (total oxidisable precursors) analysis, is recommended to check the 25 ppb and 250 ppb limits.

Above 50 mg/kg total fluorine there is also a paperwork duty. Article 5(5)(c) requires the manufacturer, importer or downstream user under REACH to provide, on request, proof of how much of the fluorine is PFAS or non-PFAS. Per the same summary, the updated FAQ says suppliers cannot refuse to provide the relevant documentation to the manufacturer.

Open questions

Can a screen close the file? Fieldfisher’s Belgian office notes that the Commission’s own scientific committee, RAC, has said total fluorine methods cannot separate PFAS fluorine from other fluorine, and that their quantification limits are too high to screen reliably against the lower targeted limits. In practice this probably means a clean total fluorine result is a strong first piece of evidence, while a borderline one invites further testing. Labs may also disagree: one compliance guide warns that identical samples can produce noticeably different results across labs.

How will national authorities enforce? The Commission says it is striving for a harmonised approach among national market surveillance authorities. Until that appears, a pack could be treated differently in different member states. This is my reading of the gap, not a reported dispute.

Will trace contamination get any relief? The PPWR text has no intent test. Some US law is different: BCLP’s state-by-state summary quotes a statute under which using post-consumer recycled material as feedstock, where some of it may contain PFAS, is not usually considered intentional introduction. That is one US state example, and the summary does not tie it to a threshold of the PPWR’s kind. It does show that an intent-based approach exists in law, which is the approach the UK Packaging Federation wants RAM to keep.

Does the 2028 review matter? The Commission’s notice says it will assess by 1 January 2028 whether to grant further exemptions from the plastic recycled-content obligations or revise the existing Article 7(4) exemptions. That review concerns recycled-content exemptions, and nothing I found links it to PFAS. It is still the first formal point at which evidence on contaminated feedstock could be put to the Commission.

Minimum post-consumer recycled content in plastic packaging, 2030 and 2040

The chart shows why the question grows. The minimum rises sharply between 2030 and 2040, so the volume of recycled plastic going into packs, including contact-sensitive ones, will rise with it. Many later PPWR dates read “1 January 2030, or a set period after the Commission’s act, whichever is later”, because several implementing and delegated acts are late. Teams therefore have time, though the PFAS limits already apply.

What to watch next

PackUK’s technical subgroup. Any change to the automatic red criteria would have to come before RAM 2027 applies on 1 January 2027, and I’d expect it to be shaped by what evidence producers can realistically supply.
Commission and national enforcement signals. Watch for further FAQ editions and for any common testing protocol among market surveillance authorities.
Monitoring data. The Norwegian authors call for monitoring to see whether PFAS in recycled paper falls as restrictions bite. Published trend data would show whether the background level is shrinking.
The delegated and implementing acts. Their timing sets when recycled-content minimums bite in practice.

What to do now

Ask every supplier of recycled fibre or recycled resin for total fluorine test reports, not declarations alone, and record the lab and method.
Where total fluorine exceeds 50 mg/kg, request the organic versus inorganic split and the supporting supplier documentation under Article 5(5)(c).
Screen mineral-filled plastics (talc, for example) with the second step before concluding that PFAS are present.
Map fibre-based food-contact items first, and check coatings, inks, adhesives and processing aids alongside the recycled fibre.
If you sell in the UK, model the fee effect of a possible automatic red for food packaging before the 1 January 2027 start.
Keep the evidence in the technical documentation. For certainty on a specific pack, check the regulation’s official text or take legal advice.