Article 5Chemicals

EU Packaging and Packaging Waste Regulation (PPWR) PFAS and Restricted Substances

Meet PFAS thresholds for food-contact packaging and control substances of concern.

Output: a supplier evidence strategy + testing plan + technical documentation pack you can defend.

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Author

Sorena AI

Published

Feb 21, 2026

Updated

Feb 21, 2026

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Publication metadata

Sorena AI

Published Feb 21, 2026

Updated Feb 21, 2026

Overview

PPWR addresses chemicals in packaging from two angles: (1) minimise substances of concern and protect recycling loops, and (2) set explicit limits for certain substances, including PFAS thresholds for food-contact packaging from the regulation's application date. This page focuses on operational compliance: inventory, supplier controls, testing, and documentation.

Section 1

What Article 5 requires (practical interpretation)

Article 5 requires packaging to be manufactured so the presence and concentration of substances of concern is minimised, including impacts on secondary raw materials and microplastics. It also sets specific limit values for certain substances and PFAS in food-contact packaging.

Substances-of-concern minimisation: treat as a design + procurement control, not only a compliance statement.
Heavy metals: the sum of lead, cadmium, mercury and hexavalent chromium in packaging/components must not exceed 100 mg/kg.
Food-contact PFAS: from 12 Aug 2026, food-contact packaging cannot be placed on the market if PFAS are at or above specified thresholds (unless prohibited under another EU act).

Section 2

PFAS thresholds for food-contact packaging (what to implement)

PPWR defines PFAS thresholds using targeted analysis and total PFAS/fluorine metrics. Translate these into a supplier + testing control.

Practical approach: treat PFAS as a critical characteristic for food-contact packaging and create an escalation path for exceptions and risk acceptance.

Thresholds include: 25 ppb for any PFAS (targeted analysis), 250 ppb for the sum of PFAS (targeted analysis, precursors where applicable), and 50 ppm for PFAS (including polymeric PFAS).
If total fluorine exceeds 50 mg/kg, upstream operators may need to provide proof of fluorine measured as PFAS or non-PFAS for technical documentation.
Action: define which packaging units are 'food-contact' and ensure suppliers can provide compliant declarations and test results.

Section 3

Supplier evidence strategy (what to require and how to verify)

Most teams fail because they rely on generic declarations. Build tiered evidence requirements based on risk: food-contact, coatings, inks, and barrier materials should have higher evidence rigor.

Supplier declarations: material composition, PFAS statement, heavy metals statement, and substances-of-concern disclosures.
Testing strategy: define when you need lab tests (e.g., new supplier, material change, high-risk coatings).
Change control: require notification for changes in formulation, coating, ink systems, or fluorinated processing aids.
Corrective actions: what happens when a batch fails - quarantine, recall considerations, and customer/regulator comms.

Section 4

Technical documentation checklist (Annex VII mindset)

Article 5 requires compliance to be demonstrated in technical documentation. The most important design decision is how you structure documentation so it is retrievable per packaging unit.

Unit-level dossier: BOM, suppliers, and material specifications.
Compliance evidence: declarations, test reports, sampling plan, and results.
Decision log: what thresholds apply, who approved, and what exceptions exist (with expiry dates).
Traceability: batch/lot traceability for high-risk components and food-contact lines.
Review cadence: align to supplier review cycles and any new EU restrictions or guidance.

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