PFAS in food-contact packaging: what changes from 12 August 2026

From 12 August 2026, packaging intended to come into contact with food may only be placed on the European market if it complies with the limits established under Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation – PPWR, for per- and polyfluoroalkyl substances, commonly known as PFAS.

The provision, set out in Article 5(5), concerns packaging manufacturers, importers, distributors and companies marketing packaged food products within the European Union; however, its application does not depend on the company’s business sector, but on the function of the packaging.

It may therefore also affect companies operating in the fashion, luxury, beauty or automotive sectors when they market, for example, branded gourmet products, wine & spirits, food gift boxes or packaging intended for events and hospitality.

The FAQs published by the European Commission in August 2026 also clarified several important aspects relating to the operational management of compliance.

Not an absolute ban, but concentration limits.

The first point to clarify is that the PPWR does not introduce an absolute ban on the presence of PFAS in food-contact packaging. Instead, it establishes three concentration limits that must be complied with simultaneously.

Compliance with the total fluorine threshold does not therefore exempt the packaging from complying with the limits applicable to individual PFAS substances and to the sum of PFAS.

For the total PFAS parameter, total fluorine is considered, including any contribution attributable to polymeric PFAS.

Compliance must therefore be assessed on the packaging unit as a whole.

Which packaging is covered by the restrictions?

The requirement applies exclusively to packaging intended to come into contact with food.

Particular attention may therefore be required, for example, for paper and board intended for fatty foods, takeaway containers, materials with oil-repellent or water-repellent properties, and packaging incorporating specific barrier coatings.

Packaging for medicinal products and packaging already placed on the market before 12 August 2026 do not fall within this specific restriction; the latter may remain on the market without being withdrawn.

Any PFAS restrictions established under other regulatory frameworks also remain separate, as they are based on their own requirements and timelines.

What do the European Commission FAQs clarify?

One of the most relevant aspects concerns the scope of the substances covered. The Commission clarified that no closed list of PFAS substances together with their CAS numbers will be published: the limits apply to substances falling within the PFAS definition established by the PPWR.

Collecting supplier declarations therefore plays an important role, but it should form part of a broader verification strategy.

In the current absence of a harmonised European testing protocol, the Commission also identifies total fluorine determination as a possible starting point for control activities. At the same time, technical work is continuing at European level to define a harmonised approach to verification.

The initial observations referred to by the Commission also suggest paying particular attention to packaging in which PFAS may have been intentionally used to provide specific functional properties, such as resistance to water, oils or fats.

How to prepare

The first step is to map packaging intended for food contact and identify the references characterised by potentially more critical materials, treatments or coatings.

On this basis, a risk-proportionate control plan can be developed, combining information from the supply chain with analytical evidence.

One possible approach involves an initial total fluorine screening, followed, where necessary, by targeted analyses of individual PFAS substances.

The results and supporting documentation should then contribute to the body of evidence used by the economic operator to demonstrate that the packaging complies with the applicable PPWR requirements.

How Analytical can support you

Analytical supports companies in assessing packaging compliance by defining testing plans tailored to the type of packaging and its specific risk profile.

To explore in greater detail the limits established by the PPWR, the role of total fluorine, risk assessment criteria and possible testing strategies for food-contact packaging, we have prepared a dedicated White Paper on the topic.

https://blog.analytical.it/pfas-food-contact-packaging-ppwr-2026