EU Packaging and Packaging Waste Regulation PFAS thresholds for food-contact packaging

PPWR Article 5 sets three PFAS concentration limits for food-contact packaging. From 12 August 2026, food-contact packaging may not be placed on the market if it contains PFAS at or above any of those limits.

The limits are 25 ppb (parts per billion) for any PFAS measured with targeted PFAS analysis, 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis where applicable with prior degradation of precursors, and 50 ppm (parts per million) for PFASs including polymeric PFAS. Article 5 excludes polymeric PFAS from quantification for the 25 ppb and 250 ppb measurements.

The Article 5 PFAS restriction is framed for food-contact packaging. A packaging review should therefore start by identifying whether the packaging or packaging component is food-contact packaging before applying the PPWR PFAS thresholds.

The restriction applies to the first making available of food-contact packaging on the Union market at or above the stated concentration limits. The Commission's 2026 guidance says sales and grouped food-contact packaging are generally placed on the market when filled because sealing may affect compliance, while transport and service packaging are generally placed on the market empty. Imported packaging is placed on the market after release for free circulation.

Keep evidence that connects each food-contact packaging item to the Article 5 threshold assessment and the Annex VII technical documentation file. The record should show the tested packaging or component, the method category used for the relevant threshold, and whether the result is below the PPWR limit.

If total fluorine exceeds 50 mg/kg, Article 5 says the REACH manufacturer, importer, or downstream user must, upon request, provide proof of the quantity of fluorine measured as PFAS or non-PFAS so the PPWR manufacturer or importer can draw up the technical documentation. This evidence duty is separate from the 50 ppm PFAS limit.

For enforcement, the Commission's 2026 guidance recommends a stepwise screen: total fluorine first, then confirmation of organic rather than inorganic fluorine where total fluorine exceeds 50 mg/kg, followed by total oxidisable precursor analysis for the 25 and 250 microgram-per-kilogram limits. This is Commission guidance for authorities, not a replacement for Article 5 or a universal laboratory protocol.

The common mistake is treating the PPWR PFAS rule as a broad marketing claim that all PFAS in all packaging is handled the same way. Article 5 is narrower and more measurable: it gives specific concentration limits for food-contact packaging and links compliance to technical documentation.

Another mistake is recording only a pass or fail label. The useful record identifies the packaging, the food-contact scope conclusion, the threshold applied, the measured result or supplier proof, and any separate Union-law restriction considered. There is no PPWR stock-exhaustion period for packaging produced before 12 August 2026: the Commission says packaging first placed on the market before that date may remain, but packaging first placed on the market afterward must comply.