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 PFAS concentrations meet or exceed specified limits.

Use this guide to identify covered packaging, map the three PFAS thresholds, and keep the evidence needed for technical documentation.

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Author
Sorena AI
Published
May 9, 2026
Updated
May 9, 2026
Sections
5

Structured answer sets in this page tree.

Primary sources
3

Cited legal and guidance references.

Publication metadata
Sorena AI
Published May 9, 2026
Updated May 9, 2026
Overview

PPWR Article 5 is not a generic PFAS slogan. It is a placing-on-the-market restriction for food-contact packaging at defined PFAS concentration limits, with compliance demonstrated in the technical documentation drawn up under Annex VII.

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 PFAS 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 therefore narrow: confirm that the item is food-contact packaging, identify the relevant packaging material or component, check the PFAS result against the Article 5 thresholds, and record whether a separate Union-law restriction already applies.

  • Scope gate: the Article 5 PFAS 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 PFAS concentration.
  • Evidence gate: compliance with Article 5(5) must be demonstrated in technical documentation under Article 5(6).
Sources for this answer
Regulation (EU) 2025/40 on packaging and packaging waste
Article 5(5) gives the food-contact packaging scope, application date, and placing-on-the-market restriction for PFAS.
Regulation (EU) 2025/40 on packaging and packaging waste
Article 5(6) requires Article 5(5) compliance to be shown in technical documentation drawn up under Annex VII.
Section 2

Which PFAS thresholds must be checked?

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

The 25 ppb and 250 ppb checks exclude polymeric PFAS 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 PFAS measured with targeted PFAS analysis, with polymeric PFAS excluded from quantification.
  • 250 ppb for the sum of PFAS measured as targeted PFAS analysis, where applicable with prior degradation of precursors, with polymeric PFAS excluded from quantification.
  • 50 ppm for PFASs including polymeric PFAS.
  • If total fluorine exceeds 50 mg/kg, keep proof of the fluorine quantity measured as PFAS or non-PFAS when requested.
Sources for this answer
Regulation (EU) 2025/40 on packaging and packaging waste
Article 5(5)(a) and Article 5(5)(b) set the 25 ppb and 250 ppb targeted-analysis limits and exclude polymeric PFAS from those quantifications.
Regulation (EU) 2025/40 on packaging and packaging waste
Article 5(5)(c) sets the 50 ppm PFAS limit including polymeric PFAS and explains the total-fluorine proof request.
Section 3

How should teams build the evidence file?

The evidence file should let a reviewer trace the decision from packaging scope to PFAS 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.

  • 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.
  • PFAS 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 PFAS 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.
Sources for this answer
Regulation (EU) 2025/40 on packaging and packaging waste
Article 5(5)(c) identifies the proof needed for fluorine measured as PFAS or non-PFAS when total fluorine exceeds 50 mg/kg.
Regulation (EU) 2025/40 on packaging and packaging waste
Article 5(6) is the grounding for keeping PFAS compliance evidence in the Annex VII technical documentation file.
Recommended next step

Turn PFAS thresholds into a release gate

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

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Section 4

How does this fit with wider PPWR implementation?

PFAS control is one Article 5 substance requirement inside a wider PPWR program. The Commission overview describes PPWR as applying from mid-2026 and summarises the policy direction: recyclable packaging by 2030, clearer labelling, reuse and refill measures, and a PFAS ban from August 2026.

Keep the PFAS 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 PFAS review to product release before placing food-contact packaging on the EU market.
  • Route PFAS 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 PFAS threshold as support for unrelated reuse, recycling, labelling, or penalty claims.
Sources for this answer
Packaging & Packaging Waste Regulation
The Commission PPWR overview provides public implementation context, including application from mid-2026 and the PFAS ban from August 2026.
Regulation (EU) 2025/40 on packaging and packaging waste
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.
Section 5

What mistakes should teams avoid?

The highest-risk mistake is publishing a broad claim that PPWR bans every PFAS use in every packaging format without explaining the Article 5 food-contact scope and threshold structure.

Another common mistake is copying a supplier statement into the compliance file without showing 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 PFAS threshold.
  • Do not describe polymeric PFAS the same way across all three checks; Article 5 treats them differently.
  • Do not rely on a local file path, proposal page, or private working note as a public source URL.
  • Do not turn the food-contact PFAS rule into unsupported claims about penalties, exemptions, or non-food-contact packaging.
Sources for this answer
Regulation (EU) 2025/40 on packaging and packaging waste
Article 5(5) is the source for the exact date, food-contact packaging scope, and three PFAS threshold values.
European Parliament press release on sustainable packaging rules
Parliament's public summary confirms the adopted text included a PFAS ban above certain thresholds in food-contact packaging.
Primary sources

References and citations

Packaging & Packaging Waste Regulation
environment.ec.europa.eu
Referenced sections
  • The Commission PPWR overview provides public implementation context, including application from mid-2026 and the PFAS ban from August 2026.
"PFAS will be banned from packaging from August 2026"
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