PPWR ObligationsEU Reg. 2025/40
Substances · Art. 5

The PPWR PFAS ban in food-contact packaging

PPWR Article 5 restricts PFAS in food-contact packaging placed on the EU market from 12 August 2026. The obligation attaches to placing on the market: from that date, packaging above the limits cannot be placed on the market, whatever its date of manufacture, so there is no grandfathering for goods you have not yet placed. Article 5 also carries the long-standing limit on the sum of lead, cadmium, mercury and hexavalent chromium, held at or below 100 mg/kg.

PFAS ("forever chemicals") are most often found in fibre-based food packaging with grease- and moisture-barrier coatings, which is where testing effort should concentrate first.

This is general information about Regulation (EU) 2025/40, not legal advice. Confirm anything you act on with qualified counsel or an accredited body.

What Article 5 restricts

Regulation (EU) 2025/40, Art. 5, addresses substances of concern in packaging. Two things matter most for day one:

  • PFAS in food-contact packaging. From 12 August 2026, food-contact packaging cannot be placed on the market if it contains per- and polyfluoroalkyl substances (PFAS) at or above the limits set in Article 5(5): 25 ppb for any single PFAS (targeted analysis, polymeric PFAS excluded), 250 ppb for the sum of PFAS (targeted analysis, polymeric excluded), and 50 ppm for PFAS including polymeric. Where total fluorine exceeds 50 mg/kg, you must be able to show that fluorine does not come from PFAS. The duty is on placing on the market, not on the manufacture date.
  • Heavy metals. The sum of concentrations of lead, cadmium, mercury and hexavalent chromium in packaging must not exceed 100 mg/kg (Article 5(4)), a limit carried forward from the previous packaging law and now cited under Regulation (EU) 2025/40.

The PFAS limits above are fixed in Article 5(5) of the regulation, not pending guidance. The measurement methods (targeted PFAS analysis, total-fluorine screening) and how they are applied to a given material are what an accredited lab confirms for you. Confirm your results with an accredited lab.

Why fibre-based food packaging is highest-risk

PFAS are used as grease and water barriers, so they turn up most in fibre-based food packaging, moulded-fibre bowls and trays, greaseproof papers, and paper or board with barrier coatings (for example fast-food wrappers, bakery bags, microwave popcorn bags, and takeaway containers). Plastic food-contact packaging is a lower but non-zero risk. Glass and metal rarely carry PFAS barriers, though they remain in scope for food contact. A sensible testing order is: fibre-based food packaging first, plastic food packaging next, then confirm the rest.

What to do before August 2026

  • Identify every food-contact packaging type you place on the market and flag anything fibre-based with a barrier coating.
  • Ask suppliers for a PFAS Certificate of Analysis or equivalent declaration for those items, this is the critical-path evidence, and it takes time to get back.
  • Keep the results in your compliance file alongside your Declaration of Conformity.

The report includes a ready-to-send PFAS request letter pre-filled with your company and packaging types, so you can start collecting that evidence the same day.

How this connects to your other obligations

The PFAS restriction sits alongside the Declaration of Conformity you hold for each packaging type and the recycled-content rules for plastic (Art. 7). Because it is a day-one duty with no grandfathering, it is one of the first things to close out, see the timeline.

Get this mapped to your own packaging

The report screens your packaging profile against Regulation (EU) 2025/40 and returns only the obligations that apply to you, each with its threshold, deadline and article, plus supplier letters ready to send.

Get my PPWR obligations report →

Frequently asked questions

When does the PPWR PFAS ban take effect?

The restriction on PFAS above threshold in food-contact packaging applies from 12 August 2026 under Article 5 of Regulation (EU) 2025/40. There is no grandfathering, so packaging placed on the market from that date must comply.

Which packaging is most likely to contain PFAS?

Fibre-based food packaging with grease- and moisture-barrier coatings, moulded fibre, greaseproof paper, and coated board such as fast-food wrappers, bakery bags and takeaway containers. That is where testing effort should start.

Does Article 5 cover heavy metals too?

Yes. Article 5 carries the limit on the sum of lead, cadmium, mercury and hexavalent chromium at or below 100 mg/kg, a threshold brought forward from the previous packaging law and now cited under Regulation (EU) 2025/40.

What evidence do I need for PFAS compliance?

A PFAS Certificate of Analysis or equivalent supplier declaration for each food-contact packaging type, kept in your compliance file. Because supplier turnaround is the slow step, request it well ahead of the August 2026 date.

Sources

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