From 12 August 2026, packaging that comes into contact with food may no longer contain PFAS above the thresholds in Annex II of the PPWR legislation. It is one of the few PPWR obligations that is not about paperwork, but about what is physically in your material — and that you therefore cannot solve with a policy document.
The obligation coincides with the date on which you must also be able to present a declaration of conformity. In that declaration you substantiate that you stay below the thresholds. Without test data there is nothing to substantiate.
The three thresholds
There is not one limit value, but three. They apply cumulatively — you only comply when you meet all three.
| What is measured | Limit value |
|---|---|
| Individual non-polymeric PFAS | 25 ppb (µg/kg) |
| Sum of all non-polymeric PFAS | 250 ppb (µg/kg) |
| Total PFAS, including polymeric | 50 ppm (mg/kg) |
Note the units: the first two are in parts per billion, the third in parts per million. The third threshold is therefore numerically the most generous, but it also captures the most — polymeric fluorine compounds such as PTFE do count there, and not in the first two.
How you test for it
A full PFAS analysis per substance name is expensive and slow. In practice it works the other way around: you screen for total fluorine. If you measure below 50 ppm total fluorine, the chance that you exceed one of the three thresholds is very small, and you have a defensible substantiation.
If you come out above it, targeted analysis follows: which fluorine compounds are present, are they polymeric or not, and how do they relate to the 25 and 250 ppb thresholds. Record the measurement method and the test date in your technical documentation. A test report without a method is worth little during an inspection.
Not sure whether this applies to your packaging? The PPWR Check walks through your role, market and material in eight questions and shows per pillar what applies to you. Take the PPWR Check →
Which packaging this affects
PFAS is in packaging because it repels grease and water. That is exactly what you want with:
- pizza boxes and other coated corrugated cardboard packaging
- baking paper, grease-resistant paper, deep-frying bags
- microwave popcorn bags
- cardboard trays and cups with a grease-resistant coating
- fast-food packaging, wraps, burger bags
- certain inks, glues and varnishes on the inner side
Paper and board with a grease-resistant function are therefore the first place to look. The obligation applies to the packaging and its components. A box that is clean itself, but has a sticker that is not, does not comply.
Do you import from a third country?
Then this is where your biggest risk lies. The importer must verify the declaration of conformity from the foreign manufacturer and be able to respond within ten days to market surveillance. See roles under the PPWR. A statement from your supplier that the packaging is “PFAS-free”, without an underlying test report from an accredited lab, is not proof. Ask for:
- the measurement method (total fluorine or targeted analysis)
- the test report with date and lab name
- confirmation that the test was carried out on the final production version
Count on weeks, not days. So start now, and not in August.
Heavy metals: same date, different substance
Besides PFAS, from 12 August 2026 the sum of lead, cadmium, mercury and hexavalent chromium in packaging and packaging components must not exceed 100 mg/kg. This is not a new standard — it was already in the packaging directive of 1994. What changes is that you now substantiate it in your technical documentation and that enforcement becomes stricter.
And the other substances of concern?
The PPWR requires that packaging is designed so that the presence of substances of concern is kept to a minimum. Concrete concentration thresholds for this follow via delegated acts — which do not yet exist. Until then, what already applied applies: above 0.1% by weight, the communication obligation under REACH Article 33 and the SCIP notification to the ECHA remain in force.
What you can do now
- Select all packaging with food contact, and within that everything with a grease-resistant or water-repellent function.
- Request a total-fluorine measurement per packaging type from your supplier, with method and report.
- Where there is no data: have it screened yourself. A total-fluorine test is relatively cheap.
- For the bottlenecks, find an alternative. PFAS-free barrier coatings exist; they work differently and sometimes have a shorter shelf life under grease.
- Record the outcomes in the technical file that sits under your declaration of conformity.