Most of what the Packaging and Packaging Waste Regulation asks of the industry arrives in 2030. One part of it arrived on 12 August 2026, and it changes specifications now. From that date, food-contact packaging cannot be placed on the EU market if it contains per- and polyfluoroalkyl substances above three separate thresholds. The limits are set on what is in the packaging, not on what migrates into the food, and they cover PFAS that were never deliberately added. That combination is what makes the restriction harder to comply with than its short text suggests.
Three limits, not one
The restriction works through three thresholds that apply in parallel. Packaging fails if it breaches any of them.
| Threshold | Applies to | Method |
|---|---|---|
| 25 ppb | Any individual PFAS | Targeted analysis, polymeric PFAS excluded |
| 250 ppb | Sum of PFAS | Targeted analysis, polymeric PFAS excluded |
| 50 ppm | Total PFAS | Includes polymeric PFAS |
The gap between the second and third figure is the part worth reading twice. Targeted analysis looks for named substances from a defined list. The 50 ppm total figure does not care about the list, and it does not exclude polymers. A material can sit comfortably under 250 ppb on a targeted screen and still fail on total fluorine.
Content, not migration
Food-contact legislation usually asks how much of a substance ends up in the food. This restriction asks how much is in the packaging. A coating that holds its fluorochemicals firmly enough to pass a migration test is still non-compliant if the concentration in the material is above the limit.
The restriction also covers substances that arrived without anyone choosing them: process aids, residues from equipment, carryover from a recycled input. A supplier declaration saying that no PFAS were added is not evidence of compliance. It answers a question the regulation did not ask.
The measurement gap the Commission acknowledged
In guidance published on 5 June 2026, the Commission stated that no harmonised EU methodology exists for measuring PFAS in food-contact packaging, and recommended that authorities take a stepwise approach to enforcement from 12 August.
This is an unusual position: a binding numerical limit with no agreed way of establishing whether it has been breached. In practice it means two things. Enforcement in the first months will lean on screening rather than full quantification, typically total fluorine as a first filter with targeted analysis where the screen suggests it. And a laboratory result is only as portable as the method behind it, so anyone commissioning testing should record which method was used and against which reference, because a competent authority may not accept a number without it.
The absence of a harmonised method is a reason to document more, not less. It is not a grace period.
Why this lands on recyclers, not only converters
A recycler selling into food-contact applications inherits whatever was in the input stream. Fluorochemicals used as grease barriers in the packaging that becomes tomorrow’s feedstock do not announce themselves at the bale stage, and mechanical recycling does not remove them.
That points at input control rather than output testing. Knowing which packaging formats a stream contains is cheaper than analysing every batch of the material that comes out of it, and it is the only approach that scales. It also sharpens an existing commercial split: food-grade rPET already carries a documentation burden that technical grades do not, and this restriction adds to it.
The wider PPWR calendar, including the recycled content targets that begin on 1 January 2030, is set out in our note on the regulation’s first two weeks. The PFAS restriction is the only part of it that changes what a specification has to say this year.
Frequently asked questions
Does the PFAS restriction apply to all packaging or only food-contact packaging?
The limits that took effect on 12 August 2026 apply to packaging intended for contact with food. Other packaging is covered by different parts of the regulation and by separate chemicals legislation.
Is a supplier declaration that no PFAS were added enough?
No. The restriction covers intentionally and non-intentionally added PFAS, so a declaration about deliberate addition does not demonstrate compliance. Analytical evidence or documented input control is needed.
Which limit is easiest to breach in practice?
The 50 ppm total figure, because it includes polymeric PFAS and does not depend on a list of named substances. Material can pass a targeted screen and still exceed it.
Does the missing harmonised test method delay enforcement?
No. The limits apply from 12 August 2026. The Commission recommended a stepwise enforcement approach, which affects how authorities check compliance, not whether the obligation exists.
How does this affect recycled content in food-contact packaging?
Recyclers inherit whatever fluorochemicals were present in the input stream, and mechanical recycling does not remove them. Compliance therefore depends on controlling which packaging formats enter the stream.
