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Food Packaging Compliance

EU PPWR PFAS Limits for Food-Contact Paper Packaging in 2026

The PFAS restriction is already applicable to food-contact packaging and covers measurable concentration, not only intentionally added treatments.

EU PPWR PFAS Limits for Food-Contact Paper Packaging in 2026
Senfeng Packaging Technical TeamPublished: 2026-08-15Updated: 2026-08-15
Content scopeCurrent as of 15 August 2026. This is not legal, chemical or food-safety advice. Confirm the finished packaging, food-contact route, analytical method and all applicable EU food-contact rules with qualified specialists.

Short answer

The practical conclusion

From 12 August 2026, food-contact packaging cannot be placed on the EU market at or above any PPWR PFAS limit: 25 ppb for any PFAS measured by targeted analysis, excluding polymeric PFAS from that quantification; 250 ppb for the sum of targeted PFAS, with precursor degradation where applicable and polymeric PFAS excluded; or 50 ppm for PFAS including polymeric PFAS. When total fluorine exceeds 50 mg/kg, specified upstream actors must provide evidence of PFAS or non-PFAS fluorine on request for technical documentation. Buyers should map every contact component, obtain dated declarations and use a risk-based test plan for the finished packaging.

Confirm whether the package is food-contact packaging

Start by drawing the complete food pack. A pizza box, bakery carton or produce box can have direct contact; a printed folding carton around a sealed pouch may be secondary packaging. Liners, grease-resistant sheets, windows, coatings, adhesives and printing set-off can change the exposure route. Do not classify the package from its product name alone.

Record the food type, fat and moisture, contact area and time, filling and storage temperature, reheating or freezing, and whether the paper contacts food directly or through a functional barrier. PPWR PFAS limits do not replace the EU food-contact-material framework or good manufacturing practice. Both sets of requirements may need to be addressed.

  • Direct, incidental or secondary contact
  • Dry, fatty, moist or acidic food
  • Time, temperature and storage conditions
  • Every coating, liner, film and adhesive in the contact path

Read all three PFAS thresholds together

The restriction is triggered when food-contact packaging contains PFAS at or above any listed threshold, to the extent another EU legal act has not already prohibited that concentration. The 25 ppb and 250 ppb values use targeted analysis and exclude polymeric PFAS from quantification. The 50 ppm value includes polymeric PFAS and therefore addresses a broader total.

A supplier statement saying that PFAS was not intentionally added can be useful, but it is not identical to analytical evidence that the concentration stays below all applicable limits. Conversely, total fluorine is a screening signal and may include non-PFAS fluorine. Agree who provides formulation information, who arranges testing and how unexpected results will be investigated.

  • 25 ppb for any targeted PFAS
  • 250 ppb for the sum of targeted PFAS
  • 50 ppm for PFAS including polymeric PFAS
  • Total-fluorine evidence route where the Regulation requires it
Pastries packed in a paperboard food carton for PFAS material review
Grease resistance, direct contact and contact time should be defined before selecting the paperboard and coating system.

PPWR PFAS thresholds effective from 12 August 2026

Food-contact packaging must remain below each applicable limit. Confirm method scope and reporting limits with a qualified laboratory.

ThresholdMeasurement scopePolymeric PFAS treatmentBuyer action
25 ppbAny PFAS by targeted analysisExcluded from this quantificationCheck individual reported compounds and method limit
250 ppbSum of targeted PFAS, with precursor degradation where applicableExcluded from this quantificationReview summed result and precursor treatment
50 ppmPFAS total under the PPWR wordingIncludedConfirm broad method and interpretation
Total fluorine above 50 mg/kgEvidence route for fluorine measured as PFAS or non-PFASCan indicate broader fluorine sourcesRequest the evidence needed for technical documentation
Other food-contact rulesSafety, migration, GMP and traceability as applicableSeparate legal frameworks continueDo not treat PFAS screening as complete food-contact approval

Build the evidence chain before approving grease resistance

Food packaging often needs oil, moisture or release performance. Specify the required function and ask the paper, coating, ink and adhesive suppliers for exact product names, intended-use statements, PFAS information, revision dates and change notification. Avoid buying a generic “oil-proof paper” without knowing how the resistance is achieved.

Testing should match risk. A simple uncoated secondary carton may need a different evidence level from a directly contacting grease-resistant box. Sampling should identify the exact production material and batch, and the report should state the analytical method, reporting limits and whether precursors or polymeric PFAS are addressed. The responsible business should review the result against the legal thresholds.

  • Controlled material and coating product names
  • Supplier declaration with scope and date
  • Batch-linked sample and accredited method where required
  • Change notification for coating or formulation revisions

Keep PFAS claims and technical files precise

Avoid printing “PFAS-free” or similar language without defining the scope, threshold, method and evidence. Absolute wording can be misleading when only intentionally added PFAS were reviewed or when the test covers a limited target list. Internal purchase specifications can instead state the legal limits, required declaration and agreed test protocol.

PPWR says compliance with the heavy-metal and PFAS provisions must be demonstrated in Annex VII technical documentation. Store the bill of materials, supplier declarations, risk assessment, reports, artwork and production batch together. If food, coating, supplier or use condition changes, reassess before the next production release.

  • Claim wording matches the evidence scope
  • Legal thresholds written into the purchase specification
  • Documents linked to the final packaging type
  • Repeat orders screened for material and supplier changes

Reference sources

Official sources for further verification

Regulations, standards and distribution requirements change. Verify the current requirements for the product and destination market before production.

FAQ

Frequently asked questions

Do PPWR PFAS limits apply to paper food boxes?

Yes when the item is food-contact packaging. The restriction is material-neutral and applies to food-contact packaging at or above the listed concentrations.

Is a “no intentionally added PFAS” declaration enough?

It is useful supplier information but not automatically equivalent to proof below every concentration threshold. The responsible business should decide the evidence and testing needed for the actual risk.

Does total fluorine always mean PFAS is present?

No. Total fluorine can include PFAS and non-PFAS fluorine. PPWR includes an evidence route when total fluorine exceeds 50 mg/kg so the technical file can distinguish the source.

Are polymeric PFAS excluded from every limit?

No. They are excluded from the targeted 25 ppb and 250 ppb quantification described in PPWR, but the 50 ppm limit includes polymeric PFAS.

Does a PFAS test prove the box is fully food-contact compliant?

No. PFAS is one issue. The complete package may also need assessment under EU food-contact, good-manufacturing-practice, migration, traceability and product-specific rules.

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