Key Findings
EU regulations now prohibit the placement of food-contact packaging on the market if PFAS concentrations meet or exceed specific thresholds. These limits apply to the packaging content itself rather than the amount of substance migrating into food. Notably, there are no exceptions for packaging containing recycled materials, and manufacturing items before the deadline does not exempt remaining stocks from these rules.
Technical Details
The PPWR establishes three distinct concentration thresholds for enforcement:
- 25 parts per billion for any individual PFAS via targeted analysis.
- 250 parts per billion for the sum of targeted PFAS (including precursor degradation).
- 50 parts per million for PFAS including polymers.
Additionally, a separate REACH restriction regarding PFHxA, its salts, and related substances in paper and cardboard food-contact materials took effect on October 10, 2026.
Background & Context
Verification remains a challenge due to the gap between supplier assurances and analytical evidence. A 2025 Swedish study found that extractable organic fluorine was detected in 47% of tested paper-based packages, suggesting unintentional presence despite restrictions on intentional additions. Furthermore, analytical methods can vary; research from February 2026 by Nestlé’s Quality Assurance Center and the Centre Technique du Papier indicated that aqueous extraction may overestimate organic fluorine by failing to remove inorganic fluorides, suggesting that thermal preparation may improve distinction.
Significance & Outlook
Industry players must now integrate chemical verification into daily production and refine procurement specifications to cover the entire supply chain. Technical alternatives to fluorochemicals are emerging, such as Ahlstrom’s mechanical refining and densification to create inherent grease barriers. Other trials involving UPM, BOBST, and Siegwerk have demonstrated that combining coated and uncoated papers with water-based inks and heat-sealing lacquers can maintain print quality and sealability on existing flexographic equipment.
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