PPWR PFAS Restrictions: What Food-Contact Packaging Producers Need to Know

Article 5 of the PPWR bans PFAS in food-contact packaging effective August 12, 2026. The obligation is binary: either you have proof per packaging type, or your packaging cannot legally enter the EU market. Testing costs hundreds to thousands of euros per analysis, and with hundreds of food-contact SKUs in large portfolios, the window to complete this work is closing fast. 

This article walks you through what the regulation actually requires, which packaging types are affected first, what compliant test reports look like, and a practical prioritization framework to get you started right away.

What Article 5 Actually Says About PFAS

The PPWR introduces two chemical restrictions for packaging that enters the EU market. 

1. The first is a heavy metals limit: lead, cadmium, mercury, and hexavalent chromium combined must not exceed 100 mg/kg. This applies to all packaging types from August 12, 2026. 
2. The second is a PFAS ban. Starting August 12, 2026, forever chemicals are prohibited in food-contact packaging. Three thresholds apply: 25 ppb for any individual non-polymeric PFAS substance, 250 ppb for the sum of all non-polymeric PFAS detected through targeted analysis, and 50 ppm for total PFAS including polymeric PFAS. If total fluorine content falls below 50 ppm, the packaging is considered compliant without further testing.

A critical point: self-declarations from suppliers do not satisfy the requirement. The PPWR embeds a documented proof principle: you must hold Certificates of Analysis (CoAs) from accredited laboratories. Without laboratory-generated test reports, your packaging is considered non-compliant in the eyes of EU market surveillance, regardless of whether the packaging actually contains PFAS or not.

Which Packaging Types Are Affected First

Not all packaging types need testing at the same time. Food-contact packaging that touches food is subject to the PFAS ban immediately upon entry into force. This includes flexible wraps, thermoformed trays, pouches, bag liners, cups, bowls, plates, utensils, and closures.

Secondary packaging, transit packaging, and non-food-contact materials are generally not in scope of the PFAS ban and remain subject only to the heavy metals limits, which many companies have already addressed through existing testing programs. Note the caveat from above: where the primary packaging does not act as a sufficient functional barrier, secondary packaging can become part of the food-contact system in practice and should be evaluated accordingly.

The trickiest cases are edge cases: barrier coatings applied to food-contact surfaces, grease-resistant treatments on paper, and moisture barriers on composite materials. These coatings often historically used PFAS-based chemistry, and a coating layer may still be in direct contact with food. A practical filter is this: if the packaging touches food and it has a barrier coating, assume testing is needed.

Some companies work with recycled or post-consumer materials. If those materials were previously treated with PFAS, residual PFAS may remain. Testing residual risk is part of your compliance strategy, especially for higher-risk material streams.

When a Risk Assessment Can Be Sufficient

The PPWR requires proof of compliance – not necessarily a lab report for every packaging type. A documented risk assessment is part of the Technical Documentation and can reduce the testing burden, provided it is defensible and material-specific.

In practice: where intentional PFAS use can be documented as excluded (no fluorinated coatings, no fluoropolymer films, no fluorinated additives in the recipe), the main residual risk for many paper-based packaging types comes from the recovered fibre stream. Available studies show typical paper-based packaging often carries very low total fluorine. Elevated values are typically found where PFAS was deliberately used, such as in grease-resistant coatings.

As a pragmatic reference, Denmark has used 20 mg/kg total fluorine for several years as an orientation value to distinguish background contamination from intentional PFAS use in paper and board food-contact materials. This is not a PPWR threshold, but it is a useful anchor for risk assessment, particularly for paper and board packaging without any functional fluorine application.

Caveat: the risk assessment must be documented, methodologically traceable, and tied to the specific packaging type including recipe review, supplier chain, and assessment of the input stream (virgin fibre vs. recycled fibre). A blanket “contains no PFAS” statement without evidence does not substitute. For packaging with functional coatings, barrier layers, or any indication of possible background contamination, the lab report remains the safer route.

What a Compliant PFAS Test Report Looks Like

When you request a PFAS test from a supplier or commissioning lab, you need a Certificate of Analysis, not a supplier attestation or a promise. A usable report includes the laboratory's accreditation credential (look for ISO/IEC 17025 accreditation for PFAS testing), the specific test method applied, the date of analysis, and the exact packaging type tested. The report must name the packaging, for example "extruded LDPE film," "thermoformed CPET tray," not just "plastic packaging."

The European Commission’s draft guidance recommends a tiered testing approach.

• Tier 1 is a total fluorine (TF) screening. If the result is below 50 ppm, the packaging is compliant and no further testing is required. This is the fastest and most affordable route, costing a few hundred euros.
• Tier 2 applies when TF exceeds 50 ppm: differentiate organic from inorganic fluorine using a method such as pyrolysis-GC/MS to determine whether the fluorine signal originates from PFAS compounds.
• Tier 3 is targeted PFAS compound analysis, required when organic fluorine exceeds the threshold, to verify compliance with the 25 ppb single-substance and 250 ppb sum limits.

Targeted compound analysis (Tier 3) uses liquid chromatography and mass spectrometry (LC-MS/MS) to identify specific PFAS substances such as PFOA, PFOS, PFHxS, and others. A full suite of targeted analysis can reach several thousand euros per sample. The method reference matters: look for EN 14582 for total fluorine screening, and ISO 21675 or lab-specific methods validated against ISO 17034 for targeted compound analysis. Reports must include a limit of quantification (LOQ) below the 25 ppb threshold.

An important caveat: there is currently no fully harmonised PPWR-specific test method for the PFAS thresholds. Identical samples can produce noticeably different results across labs. The substance group itself is broad – estimates range from 12,000 to 18,000 known PFAS compounds – which makes complete individual-substance analysis impractical. That is precisely why total fluorine (TF) has become the de facto screening route. Practical consequence: document your laboratory and method choice (ISO/IEC 17025, EN 14582, ISO 21675) in the Technical Documentation, and consider duplicate analysis or a confirmatory lab when values are close to the limits.

One common red flag is a single test report claiming to represent "all packaging in the product line." PPWR compliance requires per-packaging-type proof. A test report for a 12-micron LDPE film is not valid proof for a 50-micron blown film or a laminate. Each packaging type, material, supplier, and layer composition requires its own report. 

This is where portfolio scale becomes expensive and why prioritization is critical.

How to Prioritize PFAS Testing Across a Large Portfolio

Large food-contact packaging producers manage hundreds of SKUs. Testing each at full targeted analysis costs would result in an extensive amount of testing costs and take many months. The calendar reality is stark: it is mid-April 2026. Testing turnaround is 4 to 8 weeks per batch. August is four months away. You cannot test everything in time.

Risk-based triage is the only practical approach. 

• Tier 1 is food-contact packaging with barrier coatings: grease-resistant papers, moisture barriers, oxygen barriers applied to film, or laminates. These historically hid PFAS chemistry and carry the highest risk. Test Tier 1 packaging immediately with targeted compound analysis. 
• Tier 2 is food-contact packaging without applied coatings: plain LDPE films, thermoformed PP trays, paper board used as-is. Request formal test reports from your suppliers, not self-declarations. A supplier statement that their material "is PFAS-free" is not proof. Plan targeted testing for Tier 2 on a rolling schedule through August.
• Tier 3 is non-food-contact packaging. These materials face only the heavy metals restriction, which is older and better documented. Most companies have heavy metals testing already on file. If not, address this in parallel, but Tier 3 is lower risk and lower urgency than food-contact PFAS.

What Happens If You Miss the Deadline

August 12, 2026, is not a soft date. On that date, food-contact packaging without proof of PFAS compliance cannot legally be placed on the EU market. There is no grandfathering provision: packaging manufactured before August 12 but placed on the EU market after that date must comply. Existing stock is not exempt. Distributors, retailers, and customs authorities will reject shipments. Importers and producers bear the liability, not suppliers.

Market surveillance authorities have the power to request your Technical Documentation file within 10 days of a shipment query. Technical Documentation must include the PFAS test reports for each packaging type. If a packaging type lacks a test report, that packaging is presumed non-compliant. You cannot produce the report later and retroactively comply. The burden of proof is on the producer from day one.

Non-compliance can trigger product recalls, fines and market exclusion. While specific, uniform fines are still being finalized, penalties must be "effective, proportionate, and dissuasive". Fines could mirror GDPR-level penalties, reaching up to 4% to 5% of annual turnover for severe or repeated breaches. For global companies with operations in the EU, the risk is material.

How to Start Today

1. Identify all food-contact packaging types in your portfolio. Create a simple list: material type (LDPE film, CPET tray, coated board), thickness or gauge, application (beverage wrap, meat tray, dry goods pouch), and supplier. This audit takes a few days if you have a product database. If you do not, start with your top 20 SKUs by volume.
2. Request formal Certificates of Analysis from your suppliers. Do not ask for self-declarations or supplier letters. Request the CoA for each specific packaging type, including the accreditation number of the testing lab and the test method used. Tell suppliers you need the reports in hand within 4-6 weeks to allow time for any follow-up testing.
3. Prioritize barrier-coated packaging immediately. Identify any food-contact material with a coating, treatment, or laminate. These are Tier 1 and should go to an accredited lab for testing within the next two weeks if you do not have CoAs already.
4. Build a tracking system. A simple spreadsheet with columns for packaging type, supplier, CoA status (received/pending/testing), test date, and pass/fail result will become indispensable. We recommend our Collective Proof Platform to track test report status and completion across packaging types in a single source of truth.

PFAS compliance is fundamentally a data collection and management problem at scale. The regulation is clear, the deadline is fixed, and the consequence of non-compliance is exclusion from the EU market. Waiting for test results in July is too late. Act now with the support of Sunhat to map your gaps, prioritize your testing, and close the loop before August 12.

Book a scope assessment with Sunhat to map your PPWR PFAS testing gaps and create a prioritized action plan before August 2026.