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 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 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 placing food-contact packaging on the market at or above the stated concentration limits. Article 5 also says the PPWR restriction applies to the extent that another Union legal act has not already prohibited placing that PFAS concentration on the market.

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 manufacturer, importer, or downstream user must, upon request, provide proof of the quantity of fluorine measured as PFAS or non-PFAS so the manufacturer or importer can draw up the technical documentation.

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.