PPWR PFAS Limits for Food-Contact Packaging: 25 ppb, 250 ppb and 50 ppm since 12 August 2026

Since 12 August 2026, Article 5(5) of the PPWR (Regulation (EU) 2025/40) bars food-contact packaging from the EU market if it contains PFAS at or above 25 ppb for any single PFAS, 250 ppb for the sum of PFAS or 50 ppm for all PFAS including polymeric PFAS. The three values are concentration limits for one packaging category, the first two measured by targeted PFAS analysis, the third covering all PFAS including polymers. A separate measurement, total fluorine above 50 mg/kg, decides when a chemical supplier must prove where the fluorine comes from.

The PFAS limits sit in Article 5 of the EU Packaging and Packaging Waste Regulation (PPWR), next to the heavy-metal limit that covers all packaging. The rule is a set of maximum concentrations, not a ban: food-contact packaging that stays below all three values may be placed on the market.

This page explains the values, the PFAS definition, which packaging is caught, what happens to stock placed on the market before 12 August 2026, the testing sequence recommended by the Commission, who must document compliance and who enforces it.

Compiled by the PackagingRegulation.org Editorial Team from the Regulation's text on EUR-Lex and the cited official sources; every value on this page is checked against EUR-Lex and Commission guidance, see our methodology and fact-checking.

The key facts of the PPWR PFAS rule are summarised in the table below.

What Are the PPWR PFAS Limits for Food-Contact Packaging?

The PPWR PFAS limits are three concentration values in Art. 5(5)(a) to (c): 25 ppb, 250 ppb and 50 ppm, each measured differently. Food-contact packaging is not placed on the market if it reaches any one of them, so a packaging unit must stay below all three at the same time. The values rise by a factor of ten from (a) to (b) and by a factor of 200 from (b) to (c).

The table below sets out what each limit measures and whether polymeric PFAS count.

25 ppb for any single PFAS (targeted PFAS analysis)

Under Art. 5(5)(a) PPWR, no single PFAS may reach 25 ppb (25 µg/kg) when measured with targeted PFAS analysis, with polymeric PFAS excluded from quantification. The 25 ppb value applies to each PFAS separately: one substance at 25 µg/kg is enough to keep the packaging off the market, whatever the levels of the others.

250 ppb for the sum of PFAS (targeted analysis with precursor degradation)

Art. 5(5)(b) PPWR caps the sum of PFAS at 250 ppb (250 µg/kg), measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors, again excluding polymeric PFAS. The sum limit adds up the targeted results, so a sample in which every single PFAS stays below 25 ppb can still exceed 250 ppb in total.

50 ppm for all PFAS, including polymeric PFAS

Art. 5(5)(c) PPWR sets 50 ppm (50 mg/kg) for PFAS including polymeric PFAS, which makes it the only one of the three values that counts polymers. Polymeric PFAS are excluded from quantification under limits (a) and (b). Limit (c) is the only value that brings them into the count. Point (c) also contains a separate trigger: if total fluorine, a different measurement, exceeds 50 mg/kg, the REACH supplier must provide proof on request.

Is 50 mg/kg total fluorine a fourth PFAS limit?

No: 50 mg/kg total fluorine in Art. 5(5)(c) PPWR is the point above which the REACH supplier must, on request, prove how much fluorine is PFAS and how much is not. Total fluorine also includes fluorine that is not PFAS, such as inorganic fluorine. A result above 50 mg/kg total fluorine therefore starts a proof obligation; it does not by itself mean that the packaging breaches Art. 5(5).

Is the PPWR PFAS Rule a Ban?

No: the PPWR sets maximum PFAS concentrations for food-contact packaging and does not establish a PFAS ban. The Commission's PPWR FAQ (non-binding), section III, puts it in one sentence: "The PPWR does not establish a PFAS ban but rather sets maximum concentration levels." Packaging below 25 ppb, 250 ppb and 50 ppm complies with Art. 5(5), whichever PFAS it contains.

Art. 5(5) applies "to the extent that placing on the market is not prohibited pursuant to another Union legal act". The Commission's PPWR FAQ (non-binding) states that the PFAS limits will not be taken over into food contact materials, POPs or REACH legislation.

Does food-contact packaging have to be PFAS-free?

Not in the legal sense: food-contact packaging complies when every PFAS measurement stays below the three limit values, since the PPWR sets concentration limits, not a zero rule. The limits count intentionally added PFAS and unintentionally present PFAS alike, so PFAS that are present without being added on purpose count towards the same 25 ppb, 250 ppb and 50 ppm. Preliminary laboratory analyses of selected packaging, reported in the Commission's PPWR FAQ (non-binding), section III, found that only packaging with intentionally added PFAS exceeded the limits.

What Counts as PFAS under Article 5(5) PPWR?

PFAS (per- and polyfluorinated alkyl substances) are, under Art. 5(5) PPWR, any substance with at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom without hydrogen, chlorine, bromine or iodine attached to it. The definition is structural: it does not name substances, so every molecule with that feature is a PFAS for the limit values. Substances that contain only CF3-X or X-CF2-X′ groups, where X and X′ are specified ether, amine, aromatic, carbonyl and similar groups, are excepted. The full definition with its exceptions is in Article 5(5) in the PPWR legal text.

Polymeric PFAS fall under the same definition but are treated differently in measurement. They are excluded from quantification under limits (a) and (b) and included under limit (c). No list of PFAS by CAS number will be published, according to the Commission's PPWR FAQ (non-binding), section III.

Which Packaging Is Food-Contact Packaging under the PPWR PFAS Rule?

The PPWR does not define food-contact packaging; the Commission reads it as packaging intended to be brought into contact with food, or already in contact with food and intended for that purpose, as per the scope of EU food legislation. That reading appears in Commission Notice C/2026/3084 (OJ C, 10.6.2026), point 5, which is non-binding. The limits attach to food-contact packaging, not to one material, so paper and board, plastic and every other packaging material are caught.

Food-contact packaging is narrower than contact-sensitive packaging. Contact-sensitive packaging is one of the PPWR definitions in Art. 3(1)(49) and also covers packaging for feed, cosmetics, medical devices and medicinal products, among others; food-contact packaging is not a defined term in Art. 3 at all.

Do the PFAS limits cover inks, coatings and adhesives?

Yes: the limits apply to the packaging unit as a whole, including inks, varnishes, glues and adhesives. The Commission's PPWR FAQ (non-binding), section III, sets out this whole-unit reading, so a PFAS-containing print layer or seal adhesive counts towards the same three values as the base material.

Since When Do the PPWR PFAS Limits Apply, and What Happens to Existing Stock?

The PFAS limits apply from 12 August 2026, the PPWR's general application date, to food-contact packaging placed on the market from that day; the Regulation itself has been in force since 11 February 2025. From 12 August 2026 the decisive question is when a given unit is placed on the market, and there is no sell-off period. The 12 August 2026 date is one of several PPWR application dates, which run up to 2040.

When is food-contact packaging placed on the market?

Sales and grouped food-contact packaging is generally placed on the market when it is filled, and transport and service packaging when empty, according to Notice C/2026/3084. The PFAS limits apply to each unit at the time it is placed on the market. The Commission distinguishes three cases, listed below.

• Sales and grouped packaging: generally placed on the market when filled.
• Transport and service packaging: placed on the market empty.
• Imported packaging: placed on the market at release for free circulation.

Can packaging placed on the market before 12 August 2026 still be sold?

Yes: packaging placed on the market before 12 August 2026 may remain on the market, but there is no transitional period for exhausting stocks, so anything placed on the market after that date must meet the limits. Notice C/2026/3084, point 5, adds that there are no exceptions for recycled material. Packaging produced before the date but not yet placed on the market need not be destroyed, according to the Commission's PPWR FAQ (non-binding), section X; it must comply with the limits at the moment it is placed on the market, for sales packaging normally the moment of filling.

How Is PFAS in Food-Contact Packaging Tested?

Notice C/2026/3084 recommends a three-step sequence for enforcement testing: total fluorine first, then pyrolysis-GC/MS, then direct TOP analysis. The sequence is a recommendation in a non-binding Commission notice, not a legal test method. How laboratories offer PFAS analysis for PPWR purposes is covered under PPWR testing and PFAS analysis.

The three steps of the Commission's testing sequence are listed below.

1. Measure total fluorine. A sample below 50 mg/kg total fluorine could be considered compliant, and on current evidence all samples that pass this first test also pass tests 2 and 3, according to the Commission.
2. Separate organic from inorganic fluorine with methods such as pyrolysis-GC/MS where total fluorine exceeds 50 mg/kg. A sample with organic fluorine below 50 mg/kg could be considered compliant.
3. Run a direct TOP (total oxidisable precursors) analysis to check the 25 µg/kg limit for single PFAS and the 250 µg/kg limit for the sum of PFAS.

Is there a harmonised EU test method or a list of PFAS?

No: Notice C/2026/3084 states that there is no harmonised method at EU level, and the Commission's PPWR FAQ (non-binding), section III, adds that no list of PFAS by CAS number will be published. Art. 5(5) itself names targeted PFAS analysis for limits (a) and (b). The same FAQ section notes that many commercial and university laboratories already offer total fluorine and total organic fluorine analysis.

Who Must Prove PFAS Compliance under the PPWR?

The manufacturer must show compliance with Art. 5(5) PPWR in the Annex VII technical documentation, and the REACH supplier must back it with fluorine data when the manufacturer or importer asks. Two roles therefore share the evidence: the packaging manufacturer, who carries the legal responsibility, and the chemical supplier, who holds the substance data. PFAS proof is one file in wider PPWR compliance, which covers every other operator duty.

Manufacturers and importers: technical documentation and the EU declaration of conformity

Art. 5(6) PPWR requires compliance with the PFAS limits to be demonstrated in the technical documentation drawn up under Annex VII, the internal production control procedure of Art. 38, and kept for 5 years (single-use) or 10 years (reusable) under Art. 15(3) PPWR. The manufacturer carries out this conformity assessment itself or has it carried out on its behalf. No notified body is involved, and the PPWR provides no CE marking and no PPWR certificate.

Before placing the packaging on the market, the importer checks that the manufacturer has carried out the Art. 38 procedure and drawn up the Annex VII documentation (Art. 18(2)(a) PPWR).

On the basis of the technical documentation, the manufacturer draws up the EU declaration of conformity under Art. 39 PPWR, following the Annex VIII model. The EU declaration of conformity page shows the Annex VIII contents and who signs it.

REACH suppliers: proof of fluorine above 50 mg/kg total fluorine

The REACH manufacturer, importer or downstream user must, on request, prove to the packaging manufacturer or importer which fluorine is PFAS and which is not when total fluorine exceeds 50 mg/kg. These suppliers are the actors defined in Art. 3, points 9, 11 and 13, of Regulation (EC) No 1907/2006 (REACH). The fluorine proof that a REACH supplier provides on request is kept in the same Annex VII documentation.

Art. 16 PPWR adds a general supplier duty: suppliers provide the manufacturer with the information and documentation needed to demonstrate conformity under Articles 5 to 11, including the Annex VII documentation. The Commission's PPWR FAQ (non-binding), section X, states that suppliers cannot refuse to provide it.

Who Enforces the PPWR PFAS Limits?

National market surveillance authorities enforce the PFAS limits under Regulation (EU) 2019/1020, without prejudice to official food controls under Regulation (EU) 2017/625. Notice C/2026/3084, point 5, names both instruments. Member States must lay down penalty rules under Art. 68 PPWR and notify them by 12 February 2027, as explained under PPWR penalties and market surveillance.

Art. 62 PPWR treats documentary gaps as formal non-compliance: a missing or incorrectly drawn up EU declaration of conformity, or Annex VII technical documentation that is missing, incomplete or erroneous (Art. 62(1)(a), (b) and (d)). If the formal non-compliance persists, Art. 62(2) PPWR leads to a prohibition of making the packaging available on the market, a recall or a withdrawal. A PFAS result above a limit value is a breach of Art. 5(5) itself, not a formal gap.

How Do the PPWR PFAS Limits Fit with Other PPWR Requirements and EU PFAS Rules?

Art. 5 PPWR sets two kinds of limit values: the PFAS limits for food-contact packaging and the 100 mg/kg limit for lead, cadmium, mercury and hexavalent chromium together in all packaging. The other design and composition rules, from recyclability to labelling, are explained under PPWR requirements for packaging.

PFAS are also restricted under REACH, for example PFHxA under Regulation (EU) 2024/2462, and a universal PFAS restriction is a pending proposal; both are covered on pfasregulation.com. Food contact materials law, Regulation (EC) No 1935/2004, is covered on foodcontactmaterials.net.

Art. 5(1) PPWR adds a minimisation duty for substances of concern in all packaging, and Art. 5(4) the heavy-metal sum limit carried over from Directive 94/62/EC. Both are explained under PPWR substances of concern.

Why will the Commission evaluate Article 5(5) by 12 August 2030?

By 12 August 2030 the Commission must evaluate whether Art. 5(5) PPWR needs to be amended or repealed to avoid overlaps with Regulations (EC) No 1935/2004, (EC) No 1907/2006 (REACH) and (EU) 2019/1021 (POPs). The aim of the review is to avoid overlapping rules on PFAS between the PPWR and those three acts. This 2030 evaluation is separate from the evaluation of Art. 5 as a whole, due by 12 August 2033 under Art. 5(9).

PFAS limits and recycled material

Recycled material gets no exception: food-contact packaging containing recyclate must meet the same PFAS limits. Notice C/2026/3084, point 5, says so expressly, so recycled paper fibre or recycled plastic counts towards 25 ppb, 250 ppb and 50 ppm like virgin material.

Recycled content works the other way round. Art. 7(5)(a) PPWR exempts food-contact plastic packaging from the PPWR recycled content targets where recyclate threatens health and compliance with Regulation (EC) No 1935/2004, but no provision exempts it from the PFAS limits.

Does the PPWR PFAS limit apply to non-food packaging?

No: Art. 5(5) PPWR covers food-contact packaging only, while the minimisation duty and the 100 mg/kg heavy-metal limit of Art. 5 apply to all packaging. Packaging for cosmetics or medicinal products is contact-sensitive under Art. 3(1)(49) but falls outside the PFAS limits unless it is also food-contact packaging.

Do the PFAS limits apply to packaging imported into the EU?

Yes: imported food-contact packaging is placed on the market when it is released for free circulation, so it must meet the limits at that moment. The importer is the person established in the Union who places the packaging from a third country on the market (Art. 3(1)(17) PPWR).

The importer may request the fluorine proof from the REACH supplier like a manufacturer. This page covers the EU rule only. What else the importer must check is set out in the PPWR obligations of importers.