EU PFAS Restrictions For Food Contact Packaging 2026: Preparing For 12 August 2026 Compliance Under The Packaging And Packaging Waste Regulation

Is Your Food Contact Packaging Ready for 12 August 2026?

With the PFAS restrictions for food contact packaging under Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR) becoming applicable on 12 August 2026, manufacturers, importers, brand owners, packaging suppliers, and food businesses should be reviewing their PFAS compliance strategies, material specifications, analytical testing, supplier documentation, and technical files.

The new requirements represent an important shift in the regulatory management of packaging materials that may contain per- and polyfluoroalkyl substances (PFAS).

PFAS have historically been used in certain packaging applications because of their resistance to grease, oil, water, heat, and chemicals. However, concerns regarding their persistence and environmental and health impacts have resulted in increasing regulatory scrutiny across Europe.

For businesses placing food contact packaging on the EU market, compliance will require more than simply reviewing intentionally added PFAS. Companies should also consider PFAS that may be present unintentionally through raw materials, recycled content, manufacturing processes, inks, coatings, adhesives, and other packaging components.

As the 12 August 2026 application date approaches, companies should ensure that their packaging portfolios, supplier controls, analytical strategies, and technical documentation are aligned with the applicable PPWR requirements.

Why EU PFAS Packaging Compliance Is a Strategic Priority

Food contact packaging is increasingly subject to stricter chemical and sustainability requirements across the European Union.

The PFAS provisions under the PPWR are particularly important because they can affect packaging placed on the EU market and require companies to assess materials and components across the packaging supply chain.

Businesses that fail to establish appropriate compliance controls may face:

• Product compliance risks
• Market access delays
• Packaging redesign requirements
• Additional analytical testing
• Supplier qualification challenges
• Documentation deficiencies
• Increased compliance costs
• Potential enforcement action
• Supply chain disruptions
• Product launch delays

PFAS compliance should therefore be treated as both a regulatory and supply chain priority.

Executive Overview

Successful compliance with the EU PFAS restrictions requires an integrated approach covering:

• PFAS regulatory assessment
• Packaging material identification
• Supplier information collection
• Chemical composition review
• PFAS screening and analytical testing
• Total Fluorine assessment
• Targeted PFAS analysis where required
• Ink, varnish and coating assessment
• Adhesive and glue assessment
• Recycled material evaluation
• Technical documentation
• Supplier declarations
• Quality control procedures
• Regulatory monitoring
• Packaging redesign where necessary

Organizations that begin their assessments before the application date can identify potential compliance gaps and implement corrective actions without disrupting production or market supply.

Understanding the EU PFAS Packaging Requirements

The Packaging and Packaging Waste Regulation (EU) 2025/40 establishes requirements designed to reduce the presence of certain substances of concern in packaging.

The PFAS restrictions are particularly relevant to food contact packaging, where PFAS may historically have been used to provide grease, oil, water, or moisture resistance.

The regulatory approach introduces concentration thresholds that companies need to consider when assessing packaging placed on the EU market.

The applicable thresholds include:

• 25 ppb for any individual PFAS
• 250 ppb for the sum of targeted PFAS, where applicable, including degradation of precursors
• 50 ppm for total PFAS, including polymeric PFAS

Companies should assess these requirements alongside the specific regulatory definitions, scope, analytical considerations, and applicable guidance.

What Are PFAS?

PFAS are a broad group of synthetic substances characterized by highly fluorinated carbon structures.

They have been used in a wide range of applications because of their:

• Chemical resistance
• Water resistance
• Oil resistance
• Grease resistance
• Thermal stability
• Low surface energy

In packaging, PFAS may be associated with certain:

• Paper and board materials
• Grease-resistant packaging
• Food service packaging
• Coatings
• Barrier materials
• Printing inks
• Varnishes
• Adhesives
• Processing aids

The broad chemical family and complex supply chains make PFAS identification challenging.

PFAS Thresholds for Food Contact Packaging

Companies should pay particular attention to the applicable concentration thresholds.

The assessment should consider the relevant regulatory definitions and analytical methodology.

A compliance program should not rely exclusively on supplier declarations because PFAS may enter packaging materials through multiple sources.

The Packaging Unit Must Be Considered as a Whole

One of the important compliance considerations is that the assessment is not necessarily limited to the primary packaging substrate.

The PFAS restriction applies to the packaging unit.

This means companies should consider associated components such as:

• Packaging substrate
• Printing inks
• Varnishes
• Coatings
• Glues
• Adhesives
• Functional barriers
• Other associated materials

A packaging material that appears PFAS-free at the substrate level may still require further assessment if other components introduce PFAS.

Intentionally Added and Unintentionally Present PFAS

Companies should distinguish between intentionally added PFAS and PFAS that may be present unintentionally.

PFAS may potentially enter packaging through:

• Raw materials
• Additives
• Processing aids
• Recycled materials
• Contaminated feedstocks
• Manufacturing equipment
• Printing systems
• Adhesives
• Coatings
• Supplier materials

Therefore, simply confirming that PFAS were not intentionally added may not be sufficient for demonstrating compliance.

A risk-based assessment should consider the complete material and supply chain.

Analytical Testing and PFAS Screening

Analytical testing is expected to become an increasingly important part of PFAS compliance programs.

Until harmonized EU analytical methods are available, the regulatory guidance recommends a stepwise enforcement approach.

Companies should consider beginning with:

Step 1 – Total Fluorine Screening

Total Fluorine (TF) testing can provide an initial indication of fluorinated substances within the packaging.

Step 2 – Additional Analytical Assessment

Where Total Fluorine screening indicates a potential concern, additional analysis may be required to determine whether relevant PFAS are present.

Step 3 – Targeted PFAS Analysis

Targeted analytical methods can provide additional information regarding specific PFAS and relevant concentration levels.

This stepwise approach can help companies prioritize laboratory resources and focus detailed investigations on higher-risk materials.

Why Total Fluorine Testing Matters

Total Fluorine testing can serve as an initial screening tool in a PFAS compliance strategy.

However, Total Fluorine should not automatically be treated as equivalent to a direct measurement of regulated PFAS.

A positive fluorine screening result may require additional investigation to determine:

• The source of fluorine
• Whether PFAS are present
• Which PFAS are present
• Whether polymeric PFAS are involved
• Whether the applicable regulatory thresholds are exceeded

Companies should therefore develop testing strategies that reflect the regulatory requirements and the characteristics of their packaging materials.

Recycled Content and PFAS Compliance

The use of recycled material does not create a general exemption from the applicable PFAS limits.

The PFAS requirements apply irrespective of whether packaging contains recycled content.

Companies using recycled materials should therefore assess:

• Recycled feedstock quality
• Supplier controls
• Historical chemical use
• Contamination risks
• Analytical data
• Material specifications
• Supplier declarations

Recycled-content packaging should be incorporated into the same overall PFAS compliance assessment.

No Stock Exhaustion Period

An important practical consideration is the absence of a general stock exhaustion period for the PFAS restriction.

Food contact packaging placed on the market from 12 August 2026 must comply with the applicable requirements.

Packaging placed on the market before that date may continue to be made available, subject to the applicable regulatory conditions.

This makes inventory planning particularly important for companies holding significant packaging stocks.

Organizations should determine:

• Which products are affected
• When packaging is placed on the market
• Existing inventory quantities
• Production schedules
• Import timelines
• Customer delivery schedules
• Replacement packaging availability

Supply Chain Compliance

PFAS compliance cannot be managed effectively by packaging manufacturers alone.

Food companies, converters, packaging suppliers, raw material manufacturers, printers, coating suppliers, and adhesive suppliers may all have roles in the compliance chain.

Companies should establish supplier controls covering:

• Material specifications
• PFAS declarations
• Chemical composition information
• Analytical test reports
• Certificates of analysis
• Manufacturing process information
• Change notifications
• Supplier audits
• Regulatory declarations

Supplier documentation should be periodically reviewed rather than treated as a one-time compliance exercise.

Packaging Material Risk Assessment

Organizations should classify packaging materials according to their potential PFAS risk.

Higher-Risk Applications

Potentially higher-risk applications may include packaging historically designed for:

• High grease resistance
• Oil resistance
• Water resistance
• Moisture barriers
• Specialized food-service applications

Medium-Risk Applications

These may include materials containing:

• Specialty coatings
• Functional barriers
• Complex printing systems
• Multiple adhesive layers

Lower-Risk Applications

These may include materials with:

• Simple compositions
• Well-characterized raw materials
• Strong supplier controls
• Established analytical history

Risk classification should be based on the actual composition and manufacturing process rather than packaging type alone.

Supplier Documentation Requirements

Companies should consider requesting appropriate documentation from packaging and raw material suppliers.

Important documentation may include:

• PFAS-free declarations
• Material specifications
• Composition statements
• Analytical reports
• Total Fluorine results
• Targeted PFAS test results
• Certificates of analysis
• Change-control notifications
• Regulatory compliance statements

Supplier declarations should be supported by appropriate evidence where the risk profile justifies additional verification.

Technical Documentation

A robust PFAS compliance file should contain sufficient evidence to demonstrate how the company assessed the packaging.

Documentation may include:

• Packaging specifications
• Bill of materials
• Supplier declarations
• Risk assessments
• Laboratory reports
• Total Fluorine results
• Targeted PFAS results
• Coating specifications
• Ink specifications
• Adhesive specifications
• Change-control records
• Compliance statements
• Corrective action records

Strong documentation can improve regulatory readiness and support responses to customer or authority requests.

Impact on Packaging Design

The new PFAS requirements may require some companies to reconsider packaging designs.

Potential actions may include:

• Replacing PFAS-containing coatings
• Reformulating barrier systems
• Changing grease-resistant materials
• Selecting alternative adhesives
• Reviewing printing systems
• Replacing fluorinated processing aids
• Redesigning packaging structures
• Qualifying alternative suppliers

Packaging redesign should be evaluated carefully because changing one component may affect:

• Food contact performance
• Shelf life
• Barrier properties
• Mechanical strength
• Printing quality
• Scalability
• Manufacturing efficiency

Regulatory compliance should therefore be integrated with packaging development and quality assurance.

Food Contact Safety Considerations

PFAS compliance should be integrated into the broader food contact material compliance framework.

Companies should evaluate packaging in relation to:

• Food contact requirements
• Chemical migration
• Material Composition
• Intended food types
• Temperature conditions
• Contact duration
• Packaging function
• Applicable EU requirements

PFAS assessment should therefore form part of a broader food contact material compliance strategy rather than being managed as an isolated chemical assessment.

Regulatory Readiness Assessment

Common Compliance Challenges

Organizations may encounter:

• Limited supplier transparency
• Incomplete chemical composition data
• Lack of PFAS testing
• Unclear recycled material composition
• Complex packaging structures
• Multiple global suppliers
• Inconsistent supplier declarations
• Analytical method limitations
• Packaging redesign challenges
• Tight implementation timelines

Early assessment can significantly reduce these risks.

Common Mistakes to Avoid

Companies should avoid:

• Assuming PFAS-free means no testing is required
• Assessing only the primary packaging substrate
• Ignoring inks and coatings
• Ignoring adhesives
• Relying entirely on outdated supplier declarations
• Assuming recycled content is exempt
• Waiting until the application date to begin testing
• Failing to review existing inventory
• Using inappropriate analytical methods
• Maintaining incomplete compliance documentation

Compliance Roadmap for 12 August 2026

What Companies Should Do Before 12 August 2026

With the application date approaching, organizations should prioritize:

1. Build a Packaging Inventory

Identify all food contact packaging placed on the EU market.

2. Identify PFAS Risk

Review materials, coatings, inks, adhesives, and manufacturing processes.

3. Engage Suppliers

Request updated PFAS declarations and supporting analytical information.

4. Conduct Screening

Use Total Fluorine screening as an initial tool where appropriate.

5. Investigate Positive Results

Perform additional analysis where screening indicates potential fluorinated substances.

6. Review Existing Inventory

Determine whether affected packaging was placed on the market before or from 12 August 2026.

7. Update Documentation

Maintain evidence demonstrating the compliance assessment.

8. Prepare Alternatives

Where PFAS concerns are identified, qualify compliant alternative materials.

Future Regulatory Trends

Companies should expect continued regulatory attention toward PFAS and other substances of concern.

Emerging trends include:

• Greater chemical transparency
• Expanded PFAS restrictions
• Increased analytical testing
• Stronger supply chain due diligence
• Greater scrutiny of recycled materials
• Increased regulatory enforcement
• More detailed technical documentation
• Development of harmonized analytical approaches
• Greater integration of sustainability and chemical compliance

Organizations that establish a proactive chemical compliance program will be better positioned for future regulatory developments.

Business Benefits of PFAS Readiness

Frequently Asked Questions

1. When do the PFAS restrictions for food contact packaging apply?

The relevant PFAS provisions under the PPWR become applicable on 12 August 2026.

2. What are the PFAS concentration thresholds?

The applicable thresholds include:

• 25 ppb for any individual PFAS
• 250 ppb for the sum of targeted PFAS, where applicable
• 50 ppm for total PFAS, including polymeric PFAS

3. Does the requirement apply to the whole packaging unit?

Yes. The assessment should consider the packaging unit, including relevant components such as inks, varnishes, glues, and adhesives.

4. Does the restriction apply to unintentionally present PFAS?

The requirements are not limited to intentionally added PFAS. Companies should therefore consider potential unintentional presence when assessing compliance.

5. Is Total Fluorine testing sufficient?

Total Fluorine can be useful as a screening step, but additional analysis may be required where fluorine is detected to determine the nature and relevance of the fluorinated substances.

6. Is recycled packaging materials exempt?

No general exemption is provided simply because packaging contains recycled material. The applicable PFAS limits apply irrespective of recycled content.

7. Is there a stock exhaustion period?

There is no general stock exhaustion period for packaging placed on the market from 12 August 2026. Packaging placed on the market before that date may continue to be made available, subject to the applicable conditions.

8. Should companies test ink and coating?

Yes. Because the assessment concerns the packaging unit, associated inks, coatings, varnishes, glues, and adhesives should be considered.

9. Why is supplier documentation important?

Supplier information helps companies understand material composition, identify PFAS risks, support analytical testing strategies, and maintain technical compliance records.

10. How can Maven Regulatory Solutions help?

Maven Regulatory Solutions can support organizations with:

• PFAS regulatory assessments
• Food contact packaging compliance
• Packaging gap assessments
• Supplier documentation review
• PFAS testing strategy
• Technical documentation
• Regulatory intelligence
• Compliance gap analysis
• Packaging change assessment
• Regulatory strategy and consulting

Conclusion

The 12 August 2026 application date for the PFAS restrictions under the EU Packaging and Packaging Waste Regulation represents an important compliance milestone for companies placing food contact packaging on the EU market.

Successful compliance requires more than confirming that PFAS were not intentionally added.

Organizations should assess the entire packaging unit, including substrates, inks, varnishes, coatings, glues, adhesives, and other relevant components. They should also establish appropriate supplier controls, conduct risk-based analytical testing, evaluate recycled materials, review inventory, maintain technical documentation, and prepare alternative packaging solutions where necessary.

With the implementation date approaching, proactive PFAS assessment can help companies reduce regulatory risk, strengthen supply chain resilience, avoid packaging disruptions, and maintain continued access to the EU market.

Why Choose Maven Regulatory Solutions?

Maven Regulatory Solutions provides regulatory and compliance support for organizations navigating complex chemical, packaging, food contact, and global regulatory requirements.

Our expertise includes:

• PFAS regulatory assessment
• Food contact material compliance
• Packaging compliance strategy
• Regulatory gap assessments
• Supplier compliance review
• Analytical testing strategy
• Technical documentation
• Regulatory intelligence
• Chemical regulatory compliance
• Global market access support

We help organizations identify regulatory risks early, strengthen compliance systems, and prepare their products and supply chains for evolving regulatory requirements.