Most of PPWR is a paperwork obligation: record something, assess something, hold a declaration on file. The PFAS restriction is not. It is a prohibition on placing packaging on the market, and it took effect on 12 August 2026 with no transition period for existing stock.

If you sell food or drink in the EU, this is the PPWR requirement most likely to stop a shipment, and it is the one that depends most heavily on information you do not hold yourself.

The thresholds

Food-contact packaging cannot be placed on the EU market if it contains PFAS at or above any of the following limits:

  • 25 ppb (25 micrograms per kilogram) for any individual PFAS, measured by targeted analysis, excluding polymeric PFAS
  • 250 ppb for the sum of PFAS, measured by targeted analysis, excluding polymeric PFAS
  • 50 ppm (50 milligrams per kilogram) for total PFAS, including polymeric PFAS

The three limits are not alternatives. Packaging has to sit below all of them. The first two are measured against a defined list of substances that a laboratory can quantify individually, and they exclude fluoropolymers. The third catches everything, fluoropolymers included, at a much higher threshold.

The practical consequence of the polymeric exclusion is that a PTFE-coated component is not judged against the 25 ppb limit for the polymer itself, but any residual monomers, processing aids and non-polymeric impurities in that coating are. A coating supplier who answers "our coating is a fluoropolymer, so it is excluded" has answered the wrong question.

Total fluorine is the screening step, not the limit

Testing every food-contact component against a full targeted PFAS panel would be ruinously expensive, so the Commission has set out a stepwise approach that starts with a much cheaper measurement.

The first step measures total fluorine in the packaging. A sample below 50 mg of total fluorine per kilogram of packaging can be treated as compliant, because there is not enough fluorine present for the PFAS limits to be breached. That single test clears the large majority of a typical portfolio.

If total fluorine comes back above 50 mg/kg, the fluorine may still be inorganic - from a pigment, a filler or a mineral component - rather than from PFAS. The second step distinguishes organic from inorganic fluorine. A sample below 50 mg of organic fluorine per kilogram can likewise be treated as compliant.

Only samples that fail both screening steps need to go to targeted analysis against the 25 ppb and 250 ppb limits. Structuring your testing programme this way is the difference between a manageable spend and an unmanageable one, and it is worth agreeing the sequence with your laboratory before you commission anything.

Where the fluorine usually comes from

PFAS in food packaging is overwhelmingly functional: it is there to resist grease, water or heat. The recurring sources are worth listing, because they tell you where to start sampling:

  • Grease-resistant paper and board - bakery bags, burger wraps, chip trays, pet food liners, microwave popcorn bags
  • Moulded fibre - bowls, clamshells and trays where a barrier is needed without a plastic laminate
  • Coated and treated films, including non-stick and release coatings on baking and confectionery packaging
  • Printing inks, lacquers and varnishes applied to the food-contact side
  • Adhesives and sealants used in laminated structures
  • Gaskets and seals in closures, where fluoropolymer components are common

Note that several of these are the packaging types that were adopted as plastic replacements. Businesses that switched from plastic to moulded fibre or coated paper for sustainability reasons are disproportionately exposed, because the barrier performance that made the switch viable often came from a fluorinated treatment.

There is no sell-through period

The restriction applies to packaging placed on the EU market from 12 August 2026, regardless of when it was manufactured. Stock produced before the date is not grandfathered. Inventory sitting in a warehouse on 12 August is not compliant merely because it predates the restriction - it becomes non-compliant at the moment it is placed on the market.

This is the single most misread part of the requirement. If you have existing stock of an affected line, it needs to be quarantined, not run down.

What usable supplier evidence looks like

You will not test everything yourself, so most of your compliance position rests on supplier statements. Most of the statements circulating are not fit for purpose. A usable declaration does the following:

  • Identifies the specific component or article number, not the supplier as a whole or a product family
  • States compliance against the PPWR thresholds explicitly - 25 ppb single substance, 250 ppb sum, 50 ppm total PFAS - rather than against a generic "PFAS-free" claim or a different jurisdiction's standard
  • States whether the position is based on formulation knowledge or on testing, and if on testing, gives the method, the laboratory and the date
  • Covers intentionally added PFAS and known contamination separately, because "no intentionally added PFAS" is not the same as being under the limits
  • Names the person or entity making the statement and the date it was made, so it can be refreshed when a formulation changes

"PFAS-free" on its own is the least useful answer you can receive. It has no legal definition, it usually means "we did not add any", and it is silent on residuals, on recycled fibre inputs and on migration from processing equipment. Recycled paper and board deserve particular attention: PFAS-treated material entering the recycling stream carries through into new fibre, so a recycled-content claim and a low-PFAS claim are not automatically compatible.

What this means for your packaging data

A PFAS position is not a single flag on a SKU. It is a per-component assertion with an evidence trail behind it, and it changes whenever a supplier changes a coating, a fibre source or a laminate structure.

To answer the question "which of our lines are affected" without a two-week spreadsheet exercise, you need three things recorded at component level: whether the component is food-contact, what evidence exists for its substance restriction position, and when that evidence was last refreshed. Without the food-contact flag you cannot scope the question. Without the evidence link you cannot defend the answer. Without the date you cannot tell a current statement from one that predates a formulation change.

The same null-versus-zero discipline that matters for recycled content matters here. "No PFAS detected" and "we have not asked" are different states, and a system that renders both as a blank cell will quietly report the second as the first.

How it connects to the Declaration of Conformity

The DoC has to confirm that the packaging meets the applicable PPWR requirements, and the substance restrictions are among them. That means your PFAS evidence is not a separate compliance workstream that sits alongside the DoC - it is an input to it. A DoC issued for food-contact packaging without a substantiated substance restriction position is a declaration you cannot stand behind.

In practice this is what makes component-level storage worthwhile rather than optional. The DoC is issued at packaging level, the evidence exists at component level, and something has to roll one up into the other reliably enough to sign.

How Merchant Packaging supports this

Merchant Packaging records substance restriction evidence against the component, alongside material composition, recycled content and recyclability assessment. Components can be flagged as food-contact, supplier declarations and test reports attach to the component they relate to, and the declaration date is held so that stale evidence surfaces rather than sitting silently in a document library.

Because the evidence lives on the component, the platform can answer the scoping question directly: which food-contact components have no PFAS evidence, which have evidence older than your refresh interval, and which packaging units and SKUs those components appear in. That list is where a remediation programme starts, and it is also what feeds the substance restriction statement in the Declaration of Conformity.