PFAS compliance in food packaging is no longer only a laboratory question.
From 12 August 2026, Regulation (EU) 2025/40 on Packaging and Packaging Waste — the PPWR — introduces specific concentration limits for per- and polyfluorinated alkyl substances (PFAS) in food-contact packaging.
For companies placing food packaging on the EU market, however, knowing the legal limits is only the beginning. The practical questions are much more difficult: Which packaging should be investigated first? Which components or treatments deserve particular attention? What information should be requested from suppliers? Is a supplier declaration enough? When does laboratory testing make sense? Which analytical method should be requested? What is the difference between targeted PFAS testing and total fluorine? And how should the resulting evidence be incorporated into PPWR technical documentation?
Two recent scientific publications provide useful but complementary perspectives. Wack et al. developed a material-based PFAS risk matrix intended to support screening and prioritisation of food packaging under the PPWR. Hauschildt and Becker, meanwhile, reviewed twenty years of analytical research on PFAS in food-contact materials, including targeted LC-MS/MS, GC-MS, total fluorine, extractable organic fluorine, precursor analysis, non-target screening and migration studies.
Screen → investigate → test where appropriate → document
This article translates that concept into a practical workflow for packaging, procurement, quality and regulatory teams.
What are the PPWR PFAS limits for food-contact packaging?
Article 5(5) of the PPWR provides that, from 12 August 2026, food-contact packaging must not be placed on the EU market where PFAS concentrations are equal to or above the following limits:
| PPWR requirement | Limit |
|---|---|
| Any individual PFAS measured by targeted PFAS analysis | 25 ppb |
| Sum of PFAS measured by targeted PFAS analysis, where applicable following degradation of precursors | 250 ppb |
| PFAS including polymeric PFAS | 50 ppm |
For the first two limits, polymeric PFAS are excluded from quantification. For the 50 ppm criterion, polymeric PFAS are included.
The Regulation also addresses situations where total fluorine exceeds 50 mg/kg. In such cases, relevant supply-chain actors may need to provide evidence distinguishing fluorine attributable to PFAS from fluorine attributable to non-PFAS sources so that the manufacturer or importer can prepare the required technical documentation.
Total fluorine is not automatically equal to total PFAS.
Step 1: Which food packaging should be investigated first?
Testing every SKU using every available PFAS analytical technique would be expensive and may not provide proportionate additional information. A more practical starting point is therefore screening and prioritisation.
The risk-matrix approach proposed by Wack et al. is useful here because it does not assume that all packaging materials have equal PFAS relevance. The authors identify treated fibre-based materials — particularly where water- or grease-resistant functionality is required — as more relevant for PFAS investigation than materials such as untreated paper, glass or PET.
| Packaging characteristic | Question to ask |
|---|---|
| Paper or moulded fibre | Does the packaging require grease or moisture resistance? |
| Coated paper | What chemistry creates the barrier? |
| Multilayer packaging | Which layer provides the barrier properties? |
| Recycled fibre | Is the chemical history of the feedstock sufficiently understood? |
| Non-stick surface | What substance provides the release function? |
| Supplier declaration available | What evidence supports the declaration? |
| Supplier formulation unclear | Is additional investigation or testing justified? |
| Material changed recently | Does the existing assessment still represent the product? |
Important: A “high PFAS relevance” classification does not mean that packaging is non-compliant. Equally, “low relevance” does not by itself demonstrate PPWR compliance. The purpose of screening is to determine how much evidence is appropriate.
Step 2: Do not assess only the basic packaging material
One particularly useful lesson from the Hauschildt and Becker review is that saying a package is simply made from “paper” may tell us surprisingly little about its chemical construction.
Coating
A functional layer is applied to the material surface.
Lamination
One or more additional layers are attached to the substrate.
Sizing
Functional substances can be applied to the surface or incorporated into the fibre structure during manufacture.
Two food containers that both appear to be “paper packaging” may therefore require very different PFAS assessments depending on their coatings, laminates, additives and barrier systems. Material specifications should, where relevant, go beyond a simple description such as “paper” and identify the substrate, grease barrier, printing ink, adhesive, liner and recycled content.
Step 3: Build a PFAS supplier-information package
Before jumping directly to laboratory analysis, companies should understand what information already exists within the supply chain.
PFAS supplier information template
Product information
- Supplier name
- Supplier product code
- Packaging/component
- Material composition
- Intended food-contact application
- Manufacturing site
PFAS-related information
- Are PFAS intentionally added to the supplied material?
- Are fluorinated coatings or surface treatments used?
- Are fluorinated processing aids used?
- Is the grease-, oil- or water-resistant functionality based on fluorinated chemistry?
- Does the product contain recycled material?
- Has the material been analytically tested for PFAS?
- Which PFAS were included in the test scope?
- Was total fluorine measured?
- Which analytical method was used?
- What were the relevant limits of quantification?
- Which laboratory performed the testing?
- When was the analysis conducted?
- Is the complete analytical report available?
Change control
- Has the formulation changed since the test was performed?
- Has the raw-material supplier changed?
- Will the customer be informed about relevant formulation changes?
A simple statement such as “PFAS free” should ideally be accompanied by information explaining the basis on which that statement was made.
Is a supplier PFAS declaration enough?
Not necessarily. A supplier declaration can be an important piece of compliance evidence, but its usefulness depends on what supports it.
Consider the difference between “We do not intentionally add PFAS” and “Based on formulation review, upstream supplier declarations and analytical testing covering specified substances and methods, we have no indication that this material exceeds the applicable PPWR PFAS limits.” These are not equivalent statements.
The first primarily addresses intentional use. The PPWR limits, however, concern concentrations in the food-contact packaging. Companies may therefore need to consider additional sources such as impurities, process-related contamination, recycled feedstocks, precursor substances or components further upstream.
Step 4: When should packaging be tested for PFAS?
A risk assessment might indicate that further analytical verification would strengthen the compliance conclusion, for example where a material has grease- or water-resistant functionality, coating chemistry is unclear, supply-chain information is incomplete, recycled material is involved, declarations conflict, analytical information is outdated, a formulation or supplier has changed, or total fluorine screening raises additional questions.
The PPWR itself does not provide one universal analytical protocol or a single testing frequency for every packaging format. Hauschildt and Becker identify this as a major current challenge: PFAS analysis of food-contact materials still lacks a harmonised EU reference methodology covering all relevant matrices, and published methods differ substantially in extraction conditions, target analytes, migration protocols and method validation.
Asking a laboratory simply, “Can you test this packaging for PFAS?” may therefore not be sufficiently precise. A better question is: “We need analytical evidence to support assessment against Article 5(5) PPWR. Which analytical scope, sample preparation, reporting limits and complementary fluorine measurements are appropriate for this material?”
Targeted PFAS analysis: when you know what you are looking for
Hauschildt and Becker found LC-MS/MS to be the predominant analytical platform used for targeted PFAS determination in food-contact materials. Targeted analysis offers high sensitivity and compound-specific quantification, making it particularly useful when compliance needs to be assessed against specific PFAS concentrations.
But targeted analysis also has an inherent limitation: you can generally only quantify the substances included in the analytical target list. The range of PFAS examined in scientific studies has expanded considerably over time, from well-known PFCA and PFSA compounds to fluorotelomer substances, PAPs, GenX, ADONA and other emerging PFAS.
A laboratory report should therefore not merely state “PFAS tested.” It should identify which PFAS were tested.
Targeted PFAS vs total fluorine: they answer different questions
Targeted PFAS analysis
Answers: Which specified PFAS are present, and at what concentration?
Advantages include sensitivity, specificity and compound-level quantification. The limitation is that unknown or untargeted fluorinated substances may remain outside the analytical window.
Total fluorine
Answers: How much fluorine is present overall?
This may capture fluorine originating from PFAS but can also include non-PFAS fluorine.
Extractable organic fluorine
EOF measures an extractable organic fluorine fraction rather than every fluorine source in the material. Hauschildt and Becker explain that TF and EOF approaches are useful precisely because targeted methods cannot necessarily capture the complete range of fluorinated substances present in complex food-contact materials. At the same time, these sum-parameter techniques cannot individually identify all compounds responsible for the signal.
This is where the two studies fit together particularly well: the risk matrix tells you where to investigate; targeted analysis tells you which known PFAS were quantified; and broader fluorine analysis can help ask whether fluorine is present that targeted PFAS analysis does not explain.
What about non-target and suspect screening?
High-resolution mass spectrometry can also be used for suspect or non-target screening. Rather than looking only for a predetermined list of compounds, these techniques can help investigate unexpected fluorinated substances.
Hauschildt and Becker identify increasing use of high-resolution MS approaches in recent PFAS studies. However, they also note limitations including complex interpretation, quantification difficulties and the need for suitable spectral information. For most routine commercial compliance programmes, non-target analysis is therefore more likely to be an investigative tool than the first-line test for every product.
Extraction testing and migration testing are not the same thing
Extraction
Extraction attempts to remove PFAS from the packaging material so that the material’s PFAS content can be investigated.
Migration
Migration testing investigates how much of a substance transfers from the packaging into food or a food simulant under specified conditions.
Both approaches can provide valuable information, but they answer different questions. For PPWR Article 5, the legal wording establishes concentration limits in food-contact packaging. Migration testing, on the other hand, remains highly relevant to the broader food-contact-material safety question: what can transfer from the packaging into food under the intended conditions of use?
A practical PFAS laboratory request template
Sample information
- Packaging ID
- Supplier
- Material
- Specific component
- Food-contact application
- Hot/cold use
- Fatty/aqueous food
- Reusable/single use
Purpose of testing
- PPWR Article 5 assessment
- Supplier verification
- Material screening
- Investigation following elevated fluorine result
- Migration assessment
- Root-cause investigation
Analytical question
- Individual targeted PFAS
- Sum of targeted PFAS
- PFAS precursor investigation
- Total fluorine
- Extractable organic fluorine
- Suspect/non-target screening
- Migration
Information to request from the laboratory
- analytical target list
- sample preparation
- extraction procedure
- limits of detection
- limits of quantification
- reporting units
- treatment of precursor compounds
- quality-control procedures
- blank controls
- method validation/accreditation status
- measurement uncertainty, where relevant
- important limitations in interpreting the results
Step 5: Turn the investigation into a documented compliance decision
The result of the exercise should not simply be a folder containing a laboratory PDF. A stronger approach is to document why the available evidence was considered sufficient.
| Assessment field | Example |
|---|---|
| Packaging ID | FP-2026-014 |
| Material | Moulded fibre tray |
| Intended use | Hot fatty food |
| Barrier treatment | Yes |
| Supplier PFAS declaration | Available |
| Formulation information | Partially available |
| Recycled fibre | 30% |
| Initial PFAS relevance | Elevated |
| Targeted analysis | Completed |
| Total fluorine | Completed |
| Additional investigation | Not required / required |
| Assessment conclusion | Documented |
| Reassessment trigger | Supplier/formulation change |
This turns the risk matrix into a decision-management tool, rather than pretending that the matrix itself proves compliance.
How does this fit into PPWR technical documentation?
The PPWR explicitly connects Article 5 chemical requirements with technical documentation. A practical PFAS section of the technical file could therefore contain packaging identification, material and component information, the regulatory assessment, supplier evidence, the PFAS screening rationale, analytical evidence, the compliance conclusion and defined reassessment triggers.
1. Packaging identification
- product/SKU
- packaging description
- intended use
- applicable market
2. Material and component information
- substrates
- coatings
- liners
- laminates
- adhesives
- recycled content
3. Regulatory assessment
- applicability of Article 5(5)
- applicable PFAS limits
- other relevant chemical restrictions
4. Supplier evidence
- specifications
- supplier declarations
- formulation information where available
- change-control commitments
5. PFAS screening
- screening methodology
- risk/relevance classification
- justification
6. Analytical evidence
- targeted PFAS analysis
- total fluorine or EOF where relevant
- precursor or non-target investigation where necessary
- migration studies where relevant to broader food-contact safety
7. Compliance conclusion
- evidence reviewed
- identified uncertainties
- final assessment
- approval/sign-off
8. Reassessment triggers
- supplier change
- coating change
- increase in recycled content
- manufacturing-location change
- analytical-method update
- regulatory amendment
Practical PFAS compliance workflow
- Confirm that the packaging falls within the relevant food-contact scope.
- Break the packaging down into its materials and relevant components.
- Screen the packaging for PFAS relevance. Pay particular attention to functional treatments, coatings, barriers and unclear formulations.
- Collect supplier evidence. Do not stop at generic “PFAS-free” wording where further substantiation is reasonably available.
- Identify information gaps. Ask whether the available evidence actually supports assessment against the applicable PPWR limits.
- Use analytical testing where necessary. Define the regulatory question before selecting targeted PFAS, TF, EOF, precursor or other analytical approaches.
- Evaluate all evidence together. Supplier documentation, risk screening and laboratory data should support one coherent conclusion.
- Maintain the assessment within the technical documentation. Update it when relevant materials, suppliers, formulations or legal requirements change.
What businesses should avoid
“Our supplier says no intentionally added PFAS, so we comply.”
Not necessarily. Intentional use and measured concentration are different questions.
“Total fluorine is below/above X, therefore we know the PFAS concentration.”
Not automatically. Fluorine can require further attribution and interpretation.
“Our targeted PFAS test was negative, therefore there are no PFAS.”
A targeted method only addresses the substances and analytical scope included in that method.
“The risk matrix says the material is low risk, therefore no further compliance assessment is required.”
The risk matrix is a screening and prioritisation approach, not a legal conformity certificate.
“Migration passed, so the PPWR concentration limits are fulfilled.”
Migration testing and material-content assessment address different regulatory questions.
Frequently Asked Questions
Are PFAS banned in EU food packaging?
The PPWR establishes concentration limits for PFAS in food-contact packaging from 12 August 2026. Packaging at or above the Article 5(5) thresholds cannot be placed on the market, subject to the Regulation’s interaction with other applicable Union legislation.
What are the PFAS limits under the PPWR?
Article 5(5) establishes 25 ppb for an individual targeted PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for PFAS including polymeric PFAS.
Does every food package need the same PFAS testing?
No single harmonised EU analytical method is currently described for every type of food-contact packaging matrix. An analytical strategy should therefore consider the packaging material, supplier evidence, potential PFAS functionality and the specific regulatory question.
Is total fluorine the same as PFAS?
No. Total fluorine can include fluorine from PFAS and non-PFAS sources. Interpretation may therefore require additional evidence.
Is paper food packaging particularly relevant?
Not all paper packaging is equivalent. Recent research indicates higher PFAS relevance particularly where fibre-based packaging uses grease- or water-resistant treatments. Untreated paper may have a different risk profile.
Which laboratory method is commonly used for PFAS?
For targeted PFAS analysis of food-contact materials, LC-MS/MS is the predominant method reported in the scientific literature reviewed by Hauschildt and Becker. Other approaches can complement it depending on the analytical question.
Conclusion
The PPWR changes the way PFAS needs to be considered within food-packaging compliance. The challenge is not simply deciding whether to run one PFAS test.
A defensible process needs to connect material knowledge → supplier information → risk screening → analytical evidence → regulatory interpretation → technical documentation.
The risk-matrix approach proposed by Wack et al. offers a useful framework for determining where additional attention should be directed. The analytical review by Hauschildt and Becker helps explain what different testing approaches can — and cannot — tell us.
Do not test blindly. Do not rely blindly on declarations. Identify the material risk, understand the supply chain, define the analytical question and document why the resulting evidence supports your compliance conclusion.
Disclaimer
This article is my personal overview of the PPWR and recent scientific literature on PFAS in food-contact packaging. It is intended for general informational and discussion purposes only and should not be considered legal advice, an official interpretation of Regulation (EU) 2025/40, or a prescribed analytical compliance methodology.
PFAS legislation, guidance, analytical methods and their interpretation continue to develop. The appropriate compliance approach may depend on the material, product, supply chain, intended use and other applicable EU or national legislation.
I welcome comments, corrections and discussion from packaging, analytical, food-contact-material and regulatory professionals. If you interpret any of the requirements differently or know of additional technical guidance or evidence, I would be very interested in exploring it further.
References
Wack, K., Apprich, S., Bergmair, J. & Tacker, M. (2026). Development of a Risk Matrix for Assessing PFAS in Food Packaging. Foods, 15(7), 1183. DOI: 10.3390/foods15071183.
Hauschildt, C. & Becker, R. (2026). Per- and polyfluoroalkyl substances (PFAS) in food contact materials: A critical review of analytical strategies, migration behavior, and regulatory frameworks (2005–2025). Analytica Chimica Acta. DOI: 10.1016/j.aca.2026.345997.
Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste. Official text on EUR-Lex.