PFAS restrictions in food packaging apply from 12 August 2026: from that day, Article 5 of the PPWR, Regulation (EU) 2025/40, no longer allows packaging intended to come into contact with food to be placed on the market where the PFAS concentration reaches or exceeds the limit thresholds. In the Polish discussion the subject keeps returning mainly as a story “about chip boxes”. In practice the change is far broader: the restriction covers all packaging intended to come into contact with food, and it bites hardest on single-use barrier packaging made of paper and board, boxes, wrappers, grease-resistant bags, trays and cups among them. In our view, as a manufacturer of returnable packaging, the cleanest answer for the transport layer is not a new coating but a rigid HDPE/PP container that never needed a PFAS barrier in the first place.

Key takeaways

  • From 12 August 2026, Article 5(5) of the PPWR does not allow packaging intended to come into contact with food to be placed on the market where PFAS reach or exceed the thresholds: 25 ppb for a single substance and 250 ppb for the sum of PFAS (targeted PFAS analysis, excluding polymeric forms), and 50 ppm for PFAS counted together with polymeric forms.
  • There is no transitional period: packaging produced before August 2026 but exceeding the limit likewise cannot reach the market.
  • The restriction covers all packaging intended to come into contact with food; in practice it affects single-use barrier packaging above all, that is grease- and water-resistant paper and board, including boxes, wrappers, bags, trays and cups. PFAS can also be unintentional, carried in with recovered paper for example.
  • The burden of proof lies with the party placing the packaging on the market: technical documentation under Annex VII of the PPWR and, where total fluorine exceeds 50 mg/kg, the substance supplier documents at the request of the packaging manufacturer or importer what proportion is attributable to PFAS.

  • Our thesis: rigid returnable packaging in HDPE/PP provides a grease- and water-resistant barrier through the structure of the material itself, with no PFAS coatings, and the PFAS restrictions and the re-use targets in Article 29 push logistics in the same direction.

     

What exactly Article 5 restricts – and from when

The PPWR is a regulation, not a directive: it applies directly, with no national transposition, in identical wording across the whole EU from 12 August 2026. The previous packaging directive, 94/62/EC, was repealed on the same day (Article 70). The PFAS restriction is set out in Article 5(5): it concerns packaging intended to come into contact with food, and the definition of packaging (Article 3) also covers service packaging filled at the point of sale, single-use cups for takeaway drinks among them.

The Regulation sets three thresholds whose attainment or exceedance closes the route to market: 25 ppb for a single PFAS and 250 ppb for the sum of PFAS in a targeted PFAS analysis (excluding polymeric forms), and 50 ppm for PFAS counted together with polymeric forms. The definition of PFAS itself is broad: a substance containing at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, with certain structural exemptions, as Article 5(5) provides. For the conformity assessment the provision distinguishes neither between PFAS added intentionally and PFAS present unintentionally nor between the forms in which they occur; they count whether they are a constituent of the material, a coating or an additive. What decides is the measured result, not the intention: above the thresholds the packaging cannot be placed on the market, below them it remains permitted.

 

Where PFAS sit in packaging: boxes, paper, trays

PFAS, that is per- and polyfluoroalkyl substances, are valued for their resistance to grease, moisture and heat. In food packaging they served as a barrier, most often in single-use paper and board products: grease-resistant paper, boxes for hot and fatty dishes, wrappers and bags, trays, microwave packaging and disposable cups. The boxes, paper and trays in the title of this article are the first in line for the change, because that is where the barrier coating did most of its work.

The second source, easy to overlook, is unintentional PFAS. Recovered paper and recycled fibre can introduce PFAS even where nobody added them deliberately, and because the provision does not distinguish by source, such packaging is assessed against the thresholds as well. In practice the hotspots therefore have to be looked for not only in coating specifications but also in the secondary raw material. Rigid engineering plastics (HDPE/PP) are a separate case: here the barrier comes from the material itself, which we return to below.

 

“No transitional period”: stock and documentation

For planning purposes one detail matters most: the Regulation provides no transitional period for stock. Packaging produced before August 2026 but exceeding the limit likewise cannot be placed on the market. Stocking up ahead of the deadline solves nothing here.

The burden of demonstrating conformity rests on the party placing the packaging on the market. The packaging manufacturer or importer must hold technical documentation under Annex VII of the PPWR, and the testing logic is in practice two-stage: first a screening for total fluorine, and if it exceeds 50 mg/kg the substance or material supplier provides on request evidence of what proportion of the fluorine is attributable to PFAS, then a targeted PFAS analysis against the 25 and 250 ppb thresholds. For purchasing and QA this translates into concrete questions to suppliers: do they test total fluorine and run a targeted PFAS analysis, will they issue a declaration of conformity and test reports, and which SKUs carry the risk.

 

Paper or plastic: why rigid returnable packaging needs no PFAS

Here the manufacturer’s perspective comes in, not only that of a reader of the Regulation. In single-use paper or board packaging, resistance to grease and moisture has to be added on, and historically that was sometimes a coating, occasionally fluorochemical, which is to say PFAS. A rigid HDPE or PP container works differently: it is non-absorbent and washable, and the grease- and water-resistant barrier is provided by the structure of the plastic itself, with no fluorinated coating. We have been designing reusable containers since 1985, and this property of polyethylene and polypropylene has been the foundation of our food solutions from the outset. It is the nature of the material, not a measure devised for a particular rule.

That is why, wherever packaging performs a transport and logistics function, in the crates, trays and containers in which goods circulate between plant, warehouse and point of sale, a switch to rigid returnable packaging sidesteps the PFAS question at source and at the same time answers the re-use targets in Article 29 PPWR: 40% of transport packaging in re-use from 2030, an aim of 70% in 2040, and in controlled loops between sites, full reusability within a re-use system. We are not claiming that a returnable container will replace every single-use box or tray in direct serving; there the answer is PFAS-free coatings or reusable tableware. The distinction between the transport layer and direct serving contact is the key one here.

In fairness we should also mark out the economic frame: switching to returnable packaging is an investment decision, not a purchase made once and for all. The total cost takes in, among other things, buying the fleet, washing, return logistics and replacing worn containers, and the profitability calculation is directional in nature, because it depends on routes and rotation. In this article we stay with the regulation and the material; we run the TCO case separately, including in the PPWR cost calculator in our PPWR knowledge hub.

 

PFAS is not the whole story: substances of concern and recycled content

Article 5 does not end with PFAS. Paragraph 4 sets a hard limit for heavy metals: the sum of the concentration levels of lead, cadmium, mercury and hexavalent chromium in packaging or its components must not exceed 100 mg/kg. That limit covers all packaging, not only packaging intended to come into contact with food, and it applies independently of the PFAS thresholds. In practice the problem surfaces most often with dyes, pigments and metal components. Paragraph 1 requires substances of concern in packaging to be minimised; the Commission, supported by ECHA, is to present a report on their presence in packaging by 31 December 2026, and by 12 August 2030 it will assess the PFAS restriction itself with a view to amending or extending it. The second thread is recycled content: the minimum shares of recycled material in plastic packaging (Article 7) start to apply from 1 January 2030, and secondary raw material can introduce PFAS, so conformity with the thresholds has to be maintained as the recycled share rises. The third is labelling: packaging containing substances of concern will be labelled with standardised, open digital technologies from 12 August 2028, or 24 months after the implementing act is adopted if that comes later (Article 12(1)). The direction is a single one: packaging chemistry is moving from declaration to documented oversight.

 

What to do now: a plan for purchasing and QA

There is no need to wait for Polish accompanying legislation; the Regulation is already in force. Six steps for 2026:

  1. Map the PFAS hotspots. Identify single-use barrier packaging (grease- and water-resistant paper and board: boxes, wrappers, trays, cups) and, separately, materials made from recovered paper, where unintentional PFAS are the risk.
  2. Demand documentation of conformity with Article 5. Ask for declarations of conformity and test reports; ask whether the supplier tests total fluorine and runs a targeted PFAS analysis.
  3. Establish the testing logic. Total fluorine screening, and above 50 mg/kg the supplier documents the PFAS share on request, plus a targeted PFAS analysis against the 25 and 250 ppb thresholds.
  4. Assess the alternatives. PFAS-free coatings where single-use serving contact is needed; rigid returnable packaging where the transport and logistics layer does the work. Check that the alternative does not worsen recyclability.
  5. Watch the recycled content. Neither a rising share of recycled material (Article 7) nor recovered paper may push PFAS above the threshold.
  6. Build an evidence pack. Declarations of conformity, test reports, the scope of the method and the limit of quantification at the thresholds, before market surveillance or a customer asks for them.

For the wider picture of the Regulation, see our guide PPWR – what the regulation means for Polish companies. How the PFAS restrictions tie in with HACCP and re-use across an entire food plant is the subject of our article on the food sector and the PPWR. Our solutions for food plants are gathered on the packaging for food processing page, and the campaign as a whole in the PPWR knowledge hub.

 

FAQ

What are PFAS, and why were they used in food packaging? PFAS are a large group of per- and polyfluoroalkyl substances valued for their resistance to grease, moisture and heat. In food packaging they served as a barrier, chiefly in single-use paper and board products: grease-resistant paper, boxes, wrappers, trays and cups.

From when does the PFAS restriction apply, and which packaging does it cover? From 12 August 2026, under Article 5(5) of the PPWR, Regulation (EU) 2025/40. It applies to packaging intended to come into contact with food, service packaging filled at the point of sale included, takeaway cups for instance, with thresholds of 25 ppb (a single PFAS), 250 ppb (the sum of PFAS) and 50 ppm (PFAS counted together with polymeric forms).

Does the restriction also cover stock produced before August 2026? Yes. The Regulation provides no transitional period, so packaging exceeding the limit cannot be placed on the market regardless of the production date.

How do I prove conformity, and what should I ask of a supplier? The packaging manufacturer or importer must hold technical documentation (Annex VII of the PPWR). From a supplier it is worth demanding a declaration of conformity and test reports, and asking whether they test total fluorine and run a targeted PFAS analysis.

Do plastic containers contain PFAS? Rigid HDPE/PP containers need no fluorinated coatings, because the grease- and water-resistant barrier is provided by the structure of the material itself. Conformity is always confirmed by food contact documentation and a declaration of conformity.

Can PFAS end up in packaging by accident? Yes, from recovered paper or recycled raw material for example. The PPWR does not distinguish between PFAS added intentionally and PFAS present unintentionally; what counts is the result against the thresholds.