Key takeaway
What This Development Means
EU PPWR PFAS limits apply to food-contact packaging placed on the market from 12 August 2026. Businesses should confirm concentrations, testing evidence, supplier data and placement dates before affected packaging enters the EU market.
What Are The PPWR PFAS Concentration Limits?
Food-contact packaging must stay below 25 parts per billion for any targeted PFAS, 250 parts per billion for the sum of targeted PFAS, and 50 parts per million for PFAS including polymers. The regulation also requires fluorine evidence on request when total fluorine exceeds 50 milligrams per kilogram.
Can Existing Food Packaging Remain On Sale?
Packaging already placed on the EU market before 12 August 2026 may remain available and does not require withdrawal solely because of the new limits. Packaging manufactured earlier but first placed on the market after that date must comply. Businesses should retain evidence of the relevant placement date.
The EU's PPWR PFAS limits will apply to food-contact packaging placed on the market from 12 August 2026. The European Commission included the approaching application date in a 3 August milestones list, making this an immediate market-access issue for packaging makers, food and drink manufacturers, importers, distributors, retailers and brands across the European manufacturing value chain.
PPWR PFAS Limits And Concentration Thresholds
Article 5(5) of Regulation (EU) 2025/40 bars food-contact packaging at or above three thresholds: 25 parts per billion for any PFAS measured by targeted analysis, excluding polymeric PFAS from quantification; 250 parts per billion for the sum of targeted PFAS, with precursor degradation where applicable and the same polymer exclusion; or 50 parts per million for PFAS including polymeric PFAS.
If total fluorine exceeds 50 milligrams per kilogram, a chemical manufacturer, importer or downstream user must, on request, provide the packaging manufacturer or importer with evidence showing how much measured fluorine comes from PFAS or non-PFAS content. That evidence supports the technical documentation required by the regulation.
Market Placement, Stock And Supplier Evidence
The PPWR limits concern first placement on the EU market, not every later sale. Commission guidance published in June states that packaging placed on the market before 12 August may remain available and need not be withdrawn. Packaging produced earlier but first placed on the market after that date must comply. The regulation provides no general stock-exhaustion period for this PFAS requirement.
Manufacturers and brands should identify food-contact formats, coatings, inks, barriers, mould-release agents and recycled inputs that may contain fluorinated chemistry. Importers need defensible evidence linking test results to the supplied packaging specification. Distributors and retailers should preserve dates and records showing when affected packaging first entered the market.
Actions Before 12 August
Businesses should prioritise high-risk paper, fibre, plastic and coated formats, confirm which analytical method supports each threshold, and agree escalation routes for uncertain supplier declarations. The PFAS limits are binding, but many other PPWR design, labelling, recyclability and reuse provisions start later. Teams should use a requirement-by-requirement implementation plan rather than treating every PPWR duty as immediately applicable.
Summary
EU PPWR PFAS limits apply to food-contact packaging placed on the market from 12 August 2026. Manufacturers, importers, brands and retailers should confirm concentrations, testing evidence, supplier data and placement dates. Earlier packaging may remain available only if it was already placed on the market before the application date.
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