From 12 August 2026, food-contact packaging containing PFAS above strict concentration limits must not be placed on the EU market.
The deadline is approaching quickly. Businesses supplying packaged food or food-contact packaging should already be reviewing their materials, contacting suppliers and gathering the evidence needed for the Declaration of Conformity.
Waiting until August could leave businesses holding packaging that can no longer legally be placed on the market. This article explains what businesses need to know about the substance restrictions ahead of August 2026.
What are PFAS?
Per- and polyfluoroalkyl substances, commonly known as PFAS, are a large group of synthetic chemicals used for properties such as resistance to grease, oil, water and stains.
Potential applications can include:
- Grease-resistant paper and board
- Fast-food wrappers and takeaway packaging
- Baking and release papers
- Pizza boxes, trays and disposable plates
- Coatings, inks, waxes, adhesives and lacquers
- Plastic or composite food-contact packaging
PFAS are often described as “forever chemicals” because many are extremely persistent and do not break down easily in the environment.
What is changing under the PPWR?
From 12 August 2026, Article 5(5) of the EU Packaging and Packaging Waste Regulation (PPWR), will prohibit food-contact packaging containing PFAS at or above the following limits:
- 25 parts per billion for any individual PFAS, measured using targeted PFAS analysis, excluding polymeric PFAS from the calculation
- 250 parts per billion for the sum of PFAS, measured using targeted analysis and, where applicable, following the degradation of precursor substances, excluding polymeric PFAS
- 50 parts per million for total PFAS, including polymeric PFAS
The restriction is not limited to one packaging material. It can potentially apply to paper, board, plastics, coatings, inks, adhesives and other components where the finished packaging is intended to come into contact with food.
Which packaging is in scope?
The European Commission interprets food-contact packaging as packaging that:
- Is intended to come into contact with food; or
- Is already in contact with food and was designed for that purpose.
Important note:
- There is no exemption for packaging containing recycled material.
- There is no general period to exhaust non-compliant stock.
Food-contact packaging placed on the market from 12 August 2026 must comply, even where the packaging itself was manufactured or purchased before that date.
Packaging placed on the market before 12 August 2026 may remain available and does not need to be withdrawn solely because of the new PPWR restriction.
Evidence will be essential
Manufacturers will be responsible for establishing technical documentation that allows the packaging’s compliance to be assessed.
Under Annex VII of the PPWR, this documentation must include an appropriate analysis and assessment of the risks of non-compliance. Where relevant, it must also include:
- A description of the packaging and its intended use
- Information on its design, manufacture and component materials
- Relevant standards, specifications and testing methods
- The solutions used to meet PPWR requirements
- Test reports
Manufacturers must also draw up a written declaration of conformity for each packaging type.
The declaration and supporting technical documentation must generally be retained for:
- Five years after single-use packaging has been placed on the market
- Ten years after reusable packaging has been placed on the market
Where total fluorine exceeds 50 mg/kg, relevant supply-chain operators may also be required, upon request, to provide evidence showing how much of the fluorine content is attributable to PFAS and how much is from non-PFAS sources.
A simple statement that packaging is “PFAS-free” may not provide sufficient assurance unless it is supported by suitable technical evidence.
What should businesses do now?
Businesses placing food-contact packaging or packaged food on the EU market should begin preparing by:
- Mapping food-contact packaging across their product portfolio
- Identifying coatings, barriers, inks, adhesives and other higher-risk components
- Requesting specifications, declarations and recent test reports
- Reviewing the scope and reliability of supplier “PFAS-free” claims
- Establishing which packaging types require independent testing
- Identifying alternative materials where compliance cannot be demonstrated
- Preparing technical documentation and declarations of conformity
- Introducing controls for supplier, material or manufacturing changes
The deadline is closer than it appears
The PFAS restriction is one of the first major PPWR packaging-composition requirements to apply.
For businesses with extensive product ranges or complex international supply chains, confirming compliance could require several stages of supplier engagement, document review, testing and material substitution.
The key question is no longer whether PFAS rules are coming.
It is whether your business will have the evidence needed to continue placing its food-contact packaging on the EU market from 12 August 2026.
Get Ready for PPWR with Clarity
The 12 August 2026 deadline is approaching, and demonstrating PFAS compliance is only one part of the wider PPWR requirements businesses must prepare for.
Clarity’s PPWR Readiness Assessment helps businesses placing packaged goods on the EU market understand their obligations, identify compliance gaps and build a practical action plan for August 2026 and beyond.
The structured, expert-led service includes:
- A review of your role and obligations under PPWR
- An assessment of your Declaration of Conformity and Technical File requirements
- A tailored written report, priority action plan and compliance roadmap
- Declaration of Conformity templates and Technical File guidance
- A follow-up consultation with a Clarity compliance expert
- Ongoing updates as PPWR guidance and enforcement requirements develop
