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PPWRArticle 5EU

PPWR PFAS rules for food-contact packaging

From 12 August 2026, PPWR Article 5 restricts food-contact packaging placed on the EU market when concentrations meet or exceed specified limits.

This guide helps identify covered packaging, map the three thresholds, and keep the evidence needed for technical documentation.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
5 sections3 primary sources
Overview

From 12 August 2026, PPWR Article 5 prohibits placing food-contact packaging on the EU market when meets or exceeds any of its three concentration limits, unless another Union legal act already prohibits that market placement. Compliance must be demonstrated in Annex VII technical documentation.

Section 1

What does PPWR Article 5 require for food-contact packaging?

Article 5(5) says that from 12 August 2026, food-contact packaging must not be placed on the market if it contains at or above any of the listed limit values, unless another Union legal act already prohibits placing that packaging on the market.

The practical decision is narrow: confirm that the item is food-contact packaging, identify the relevant packaging material or component, check the result against the Article 5 thresholds, and record whether a separate Union-law restriction already applies. Article 5 defines PFAS by chemical structure for this restriction, so a supplier's use of a narrower substance list does not by itself establish PPWR compliance.

  • Scope gate: the Article 5 threshold restriction is framed for food-contact packaging.
  • Market gate: the restriction applies to placing covered packaging on the market from 12 August 2026.
  • Overlap gate: Article 5 preserves other Union-law prohibitions that may already restrict the same concentration.
  • Evidence gate: compliance with Article 5(5) must be demonstrated in technical documentation under Article 5(6).
Section 2

Which PFAS thresholds must be checked?

Article 5(5) lists three separate limits. Treat them as three evidence checks, not as one generic threshold.

The 25 ppb and 250 ppb checks exclude polymeric from quantification. The 50 ppm check includes polymeric PFAS and has a separate proof step when total fluorine exceeds 50 mg/kg.

  • 25 ppb for any measured with targeted PFAS analysis, with polymeric PFAS excluded from quantification.
  • 250 ppb for the sum of measured as targeted PFAS analysis, where applicable with prior degradation of precursors, with polymeric PFAS excluded from quantification.
  • 50 ppm for PFASs including polymeric .
  • If total fluorine exceeds 50 mg/kg, keep proof of the fluorine quantity measured as or non-PFAS when requested.
Section 3

How should teams build the evidence file?

The evidence file should let a reviewer trace the decision from packaging scope to result to the Article 5 limit that was applied. A pass or fail label alone is not enough.

For supplier-controlled materials, keep declarations, test reports, change notices, and the component map together so the manufacturer or importer can support the Annex VII technical documentation. If total fluorine exceeds 50 mg/kg, Article 5 places the upon-request proof duty on the relevant manufacturer, importer, or REACH downstream user in the supply chain so the PPWR manufacturer or importer can distinguish fluorine measured as from non-PFAS fluorine.

  • Food-contact scope record for each packaging item or component.
  • Material and component inventory covering coatings, barriers, inks, adhesives, substrates, and other relevant food-contact layers.
  • test result or supplier declaration mapped to the 25 ppb, 250 ppb, or 50 ppm Article 5 limit.
  • Record of whether another Union legal act already prohibits the relevant concentration.
  • Technical documentation entry showing how Article 5(5) compliance was demonstrated.
  • Total-fluorine proof record when total fluorine exceeds 50 mg/kg and proof is requested.
Recommended next step

Turn PFAS thresholds into a release gate

This PPWR guide helps map food-contact packaging, PFAS evidence, supplier inputs, and Article 5 technical documentation before EU market release.

Research workflow
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Section 4

How does this fit with wider PPWR implementation?

control is one Article 5 substance requirement inside a wider PPWR program. The Commission overview describes PPWR as applying from mid-2026 and now states that PFAS will be restricted in packaging that comes into contact with food. Article 5 supplies the precise rule: the restriction applies from 12 August 2026 when a listed concentration limit is met or exceeded.

Keep the workflow connected to packaging release gates. A material substitution may also affect recyclability, labelling, supplier declarations, and EPR records, but those adjacent changes need their own PPWR source support.

  • Connect review to product release before placing food-contact packaging on the EU market.
  • Route material changes through packaging engineering, product compliance, procurement, and legal review.
  • Update recyclability, labelling, or EPR evidence only when the material change actually affects those records.
  • Do not cite the PPWR threshold as support for unrelated reuse, recycling, labelling, or penalty claims.
Section 5

What mistakes should teams avoid?

Do not publish a broad claim that PPWR bans every use in every packaging format. Article 5(5) has a food-contact scope and three threshold checks.

A supplier statement is insufficient unless the compliance file shows which packaging component was assessed, which threshold was checked, and how the technical documentation will be maintained after a material change.

  • Do not omit the 12 August 2026 date when describing the Article 5(5) placing-on-the-market restriction.
  • Do not combine the 25 ppb, 250 ppb, and 50 ppm limits into one invented threshold.
  • Do not describe polymeric the same way across all three checks; Article 5 treats them differently.
  • Keep each supplier report identifiable by packaging component, material version, analytical method, assessment date, and the Article 5 limit it supports.
  • Do not turn the food-contact rule into unsupported claims about penalties, exemptions, or non-food-contact packaging.
Primary sources

References and citations

Regulation (EU) 2025/40 on packaging and packaging waste
data.europa.eu6 citations
Referenced sections
  • Official PPWR text for Article 5 food-contact packaging PFAS thresholds, fluorine proof requirements, and technical documentation.
  • Article 5(5) gives the food-contact packaging scope, application date, PFAS definition, placing-on-the-market restriction, and overlap condition; Article 5(6) requires compliance evidence in Annex VII technical documentation.
  • Article 5(5)(a) to (c) sets the 25 ppb and 250 ppb targeted-analysis limits, excludes polymeric PFAS from those two quantifications, and sets the 50 ppm limit including polymeric PFAS and the total-fluorine proof rule.
Show 3 more
  • Article 5(5)(c) identifies who must provide proof, upon request, of fluorine measured as PFAS or non-PFAS when total fluorine exceeds 50 mg/kg; Article 5(6) requires Annex VII technical documentation.
  • Article 5(1) requires substances of concern in packaging materials or components to be minimised, separate from the specific Article 5(5) PFAS threshold rule.
  • Article 5(5) is the source for the exact date, food-contact packaging scope, and three PFAS threshold values.
"From 12 August 2026, food-contact packaging shall not be placed on the market"
More quoted passages
"25 ppb for any PFAS as measured with targeted PFAS analysis"
"proof of the quantity of fluorine measured as content of either PFAS or non-PFAS"
"presence and concentration of substances of concern"
"in a concentration equal to or above the following limit values"
European Parliament press release on sustainable packaging rules
europarl.europa.eu2 citations
Referenced sections
  • Parliament summary confirming the rule targets PFAS above thresholds in food-contact packaging.
  • Parliament's public summary confirms the adopted text included a PFAS ban above certain thresholds in food-contact packaging.
"above certain thresholds in food contact packaging"
More quoted passages
"PFASs) above certain thresholds in food contact packaging"
Packaging & Packaging Waste Regulation
environment.ec.europa.eu2 citations
Referenced sections
  • Current Commission overview confirming PPWR implementation context and describing the PFAS measure as a restriction for packaging that comes into contact with food; Article 5 supplies the exact date and concentration limits.
  • The current Commission PPWR overview provides public implementation context and describes PFAS as restricted in packaging that comes into contact with food; Article 5 supplies the exact date and concentration limits.

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