PPWR PFAS ban 2026: food-contact packaging checklist

1. What changes on 12 August 2026?

PPWR generally applies from 12 August 2026. One of the most immediate checks for food, drink, takeaway, grocery and food-service packaging is the PFAS restriction for food-contact packaging.

Article 5(5) says that from 12 August 2026, food-contact packaging must not be placed on the market if it contains PFAS at or above the listed concentration limits, subject to the detailed wording of the Regulation and other applicable EU chemical and food-contact rules.

The rule matters because food-contact packaging often includes coatings, barriers, liners, wrappers, trays, sachets, labels, adhesives or treated paper-based materials. A business may know the outer packaging supplier but still lack evidence for the layer that actually touches food.

The risk is not just regulatory. Importers, retailers, marketplaces and food customers may start asking for supplier declarations before the application date so they can protect their own route to market.

2. Which packaging should you check first?

Start with packaging that is intended to be brought into contact with food or is already in contact with food and was intended for that purpose.

High-priority examples include:

• Takeaway cartons, cups, bowls, trays, lids and wraps.
• Paper, board or moulded-fibre food packaging with grease or moisture barriers.
• Bakery, confectionery, snack and frozen-food packaging.
• Food-service sachets, pouches, sleeves, liners and inserts.
• Labels, seals, adhesives or coatings that may form part of the food-contact packaging system.
• Imported food packaging where the EU importer does not control the upstream packaging specification.

Do not only review the visible retail pack. If a liner, film, coating or internal component performs the food-contact function, it needs to be part of the evidence trail.

3. What are the PPWR PFAS limit values?

Article 5(5) of Regulation (EU) 2025/40 sets three concentration-based PFAS limit values for food-contact packaging:

The key point for commercial teams is simple: do not rely on informal supplier statements such as “no PFAS added” unless they are supported by usable documentation.

4. What about stock produced before August 2026?

The Commission guidance states that PPWR does not provide a transitional stock-exhaustion period for food-contact packaging containing PFAS. Food-contact packaging placed on the market after 12 August 2026 must comply with the PFAS limits, while packaging placed on the market before that date may remain on the market and does not need to be withdrawn.

That distinction matters. A business should not assume that packaging manufactured before the date can automatically be used or supplied after the date. The relevant question is when the packaging is placed on the market, and how that applies to the packaging format and supply route.

5. What evidence should you collect?

Build an evidence pack by packaging format, not just by SKU. One tray, cup, wrapper or liner may be used across several products, so group the work around the packaging component that creates the food-contact risk.

Where evidence is weak, do not fill the gap with confident wording. A missing-data register is more credible than an unsupported claim.

6. Do you need lab testing?

Not every business will start with testing every component. The sensible first step is to classify packaging, identify food-contact components and request supplier evidence. Testing becomes more relevant where the material is high-risk, supplier evidence is absent, the packaging uses barrier treatments, or a retailer/importer asks for stronger proof.

The Commission guidance notes that several protocols and methodologies exist, but there is no harmonised EU methodology for PFAS in food-contact packaging yet. The guidance also describes a stepwise total-fluorine approach for enforcement from the application date.

Use qualified laboratories and technical advisers where a test decision is needed. PPWR Copilot can help organise the evidence and gaps, but it does not replace laboratory testing or legal review.

7. What should you ask suppliers?

Supplier emails need to be specific. A vague “please confirm PPWR compliance” request is easy to answer badly.

Ask for:

• Confirmation of whether each component is food-contact packaging.
• Confirmation of whether PFAS are intentionally used in any material, coating, barrier, ink, adhesive or treatment.
• Available evidence against the PPWR PFAS limit values.
• Food-contact documentation and restricted-substance declarations.
• Any test reports or certificates already available.
• Confirmation of the packaging format, material, coating and supplier scope covered by the declaration.

Make sure the declaration matches the exact packaging component you use. A general corporate policy is not the same as a component-level evidence trail.

8. Common mistakes to avoid

• Treating “PFAS-free” as a marketing phrase without evidence.
• Only checking the outer carton while ignoring liners, coatings or food-contact films.
• Assuming a non-EU supplier understands the EU PPWR threshold requirements.
• Using one supplier declaration across several packaging formats without checking scope.
• Confusing food-contact compliance generally with PPWR PFAS evidence specifically.
• Waiting for the retailer or importer to ask instead of preparing the file now.

9. What to do next

Start with a simple triage: which packaging formats touch food, which suppliers control those materials, what declarations already exist, and where are the evidence gaps?

Then turn that into a review pack. Your importer, distributor, retailer or internal QA team does not need a folder of scattered PDFs. They need a clear view of the packaging format, component evidence, source notes and open points.

For broader PPWR timing, read the PPWR August 2026 compliance checklist. For packaging label and evidence review, see the PPWR label review service.