PPWR PFAS Rules for Food-Contact Paper Packaging

What Changed on 12 August 2026?

Article 5(5) of Regulation (EU) 2025/40 applies from 12 August 2026. It provides that food-contact packaging must not be placed on the market when it contains PFAS in concentrations equal to or above the specified limits, to the extent that another Union legal act has not already prohibited the placement on the market. This is a current substance restriction, not a future 2030 design target.

The date matters at the point the packaging is placed on the EU market. Commission guidance explains that there is no general stock-exhaustion transition for food-contact packaging placed on the market after the application date. Packaging already placed on the market before that date may remain available, but later placement must be assessed against the applicable requirement. The official guidance also does not create a recycled-material exemption.

This narrow PFAS rule sits inside a much wider regulation. Buyers needing the broader paper-box roadmap should use the EU PPWR paper packaging buyer guide. N08 stays focused on the food-contact PFAS execution layer: scope, thresholds, component evidence, testing boundaries and supplier handoff.

Which Paper Packaging Is Within the Food-Contact Scope?

The Commission’s guidance interprets food-contact packaging as packaging intended to be brought into contact with food, or packaging already in contact with food and intended for that purpose, in line with Union food legislation. The intended use and actual contact route control the assessment. A paperboard takeaway box that directly holds food can follow a different route from a printed retail sleeve around a sealed inner pouch.

Do not label every carton used by a food brand as Article 5 food-contact packaging. A corrugated master carton carrying sealed retail packs, a delivery shipper that never contacts the food, or a secondary box around a closed primary container is not automatically food-contact packaging merely because food is inside the supply chain. Conversely, a coating, liner, window or adhesive in a direct or foreseeable contact route cannot be ignored simply because the main substrate is paperboard.

Commission guidance distinguishes market-placement timing by packaging function. In general, sales and grouped food-contact packaging can be placed on the market when filled because filling or sealing may influence the finished package, while transport and service packaging may be placed on the market empty. Buyers should verify the route for the actual commercial arrangement rather than copy a timing statement from a different packaging type.

Food-contact scope is also not the only legal layer. Regulation (EC) No 1935/2004 remains the general framework for materials and articles intended to contact food, while REACH restrictions and other applicable Union or national measures may also matter. PPWR Article 5 does not replace those obligations. For the broader material-selection route, keep the food-safe packaging materials guide as the owner for intended use, coatings and material verification.

The Three PPWR Article 5(5) PFAS Thresholds

Article 5(5) uses three different measurement concepts. They should not be rewritten as one interchangeable number or one universal “PFAS certificate.” The regulation states the limits as concentrations equal to or above the values below.

The unit difference is material: ppb and ppm are not interchangeable. The 25 ppb line addresses any individually targeted PFAS; the 250 ppb line addresses a sum of targeted PFAS and may involve precursor degradation; the 50 ppm line includes polymeric PFAS. A report that answers only one of these questions should not be described as answering all three without a documented technical basis.

The Commission FAQ further explains that Article 5 applies to the whole packaging unit, including relevant inks, varnishes, glues and adhesives. That interpretation reinforces the need for a component map. Testing only the base paper while an applied barrier, print system or adhesive is outside the sample scope may leave an evidence gap.

Testing, Polymeric PFAS and the Total-Fluorine Boundary

The regulation defines the concentration thresholds but does not designate one harmonised EU laboratory method that must be used for every package and every threshold. Commission Guidance C/2026/3084 describes a recommended enforcement approach while acknowledging that harmonised methodology is still under development. The guidance is an implementation aid, not a replacement for the legal text.

The Commission’s recommended stepwise direction begins with total fluorine quantification. If total fluorine is below 50 mg/kg, the sample could be considered compliant for the 50 ppm route. If total fluorine is above 50 mg/kg, further work can distinguish organic from inorganic fluorine. The guidance then recommends targeted approaches, including a direct total oxidisable precursor approach, for the 25 µg/kg and 250 µg/kg questions. This recommendation must not be rewritten as a universal statutory protocol or a guarantee that one screening result resolves every threshold.

Article 5 includes a separate evidence mechanism when total fluorine exceeds 50 mg/kg. At the request of the manufacturer or importer, the relevant manufacturer, importer or downstream user, using the REACH role definitions, must provide proof of the quantity of fluorine measured as PFAS or non-PFAS content. That information enables the manufacturer or importer to prepare the technical documentation specified in Annex VII. Total fluorine is therefore an evidence signal and accounting route; it is not automatically identical to PFAS content.

A practical testing instruction should say: the laboratory method should be appropriate to the applicable Article 5(5) threshold and evidence scope. The brief should identify the finished sample, component coverage, targeted analyte list, precursor treatment where applicable, polymeric-PFAS boundary, total-fluorine result, reporting limits, uncertainty or qualification, and the exact production revision represented.

No universal “PFAS-free certificate” is created by PPWR. A supplier declaration can be useful, and a test report can be useful, but each has a scope. If a buyer uses “PFAS-free” wording at all, it should state the tested material or component, method or analyte boundary, detection/reporting basis, supplier and revision. HS PACKFACTORY does not make an unconditional factory-wide claim that every package is PFAS-free.

Where PFAS Risk Can Appear in Paper-Packaging Projects

Grease, oil, moisture and release performance can lead buyers to focus on coatings and barriers, but function alone does not prove PFAS content. Not every grease-resistant coating contains PFAS, and not every water-resistant paper is PFAS-treated. The correct route is formulation verification against the actual supplier chemistry and intended use.

Start with the complete bill of materials. Base board, contact-side coating, lamination, liner, window film, ink, overprint varnish, adhesive, label and processing aids may each need a documented status depending on construction and contact route. Ask suppliers to identify the commercial product code and revision rather than accepting a generic statement about “paper coating.”

The food and beverage packaging page can help buyers define carton structure and use conditions. The folding cartons page covers common paperboard formats. Neither page replaces the Article 5 evidence assessment for the chosen component set.

What Buyers Should Request From Packaging Suppliers

A buyer request should be narrow enough to produce traceable evidence. “Send a PFAS certificate” is not a complete instruction. It does not define the packaging object, food-contact route, components, threshold, method scope, revision or responsible party.

1. Packaging identity: project name, SKU, drawing or dieline number, finished dimensions, intended food, contact route and market.
2. Component list: paper/board, coatings, barriers, laminations, inks, varnishes, adhesives, windows, liners, labels and inserts with supplier/product codes.
3. Supplier declarations: statements linked to the exact commercial product and revision, including limitations, excluded components and date.
4. Test-report scope: sample identity, preparation, laboratory, method, analytes, precursor handling, polymeric boundary, total fluorine, units, reporting limits and results.
5. Change control: an obligation to notify the buyer before changing the board mill, coating formula, ink, adhesive, supplier, production route or other compliance-relevant input.
6. Traceability: purchase order, batch/order reference, approved sample and production revision that connect the evidence to the goods supplied.

Article 16 requires suppliers of packaging or packaging materials to provide manufacturers with the information and documentation needed to demonstrate conformity. That supplier input supports the responsible manufacturer; it does not automatically become the final Declaration of Conformity. The manufacturer still performs the assessment, controls production and assumes responsibility for the PPWR conclusion.

When planning an RFQ, use the custom packaging quote checklist to collect size, function, materials, artwork, quantity and market data. Add the Article 5 fields above when the project is food-contact packaging for the EU.

Supplier Declarations, Test Reports and Annex VII Documentation

A supplier declaration is strongest when it identifies the legal reference, product code, component, supplier, formulation or revision, applicable threshold scope, evidence relied upon, limitations and signatory. A broad letter covering “all paper packaging” without product identity or change control is weak evidence.

A laboratory report is strongest when the sample can be tied to the approved construction. The report should make clear whether it tested a raw material, one component, a composite specimen or the finished packaging. If the report covers only the contact-side coating, the file should not imply that the ink, adhesive, window and base board were also tested.

The resulting records can feed the responsible manufacturer’s Annex VII file. The technical file should connect Article 5 applicability, risk analysis, specifications, drawings, component evidence, test reports, production control and revision history. The separate PPWR technical documentation and Declaration of Conformity guide remains the primary owner for the full Annex VII and Annex VIII workflow.

A laboratory certificate does not replace the technical file. It answers a defined analytical question; it does not identify every applicable PPWR requirement, define the economic-operator roles, control production changes or create the manufacturer’s signed Declaration of Conformity.

Material, Formulation and Supplier Change Control

Evidence becomes stale when the physical package changes. A switch in board mill, coating product, coat weight, ink series, varnish, adhesive, window film, liner, converter or production site can change the basis of the assessment. Even a change made to improve grease resistance or cost may require a new scope review.

Use a controlled revision table listing the component, old and new supplier/product code, reason for change, affected SKUs, contact route, evidence reviewed, sample/test decision, approval date and responsible reviewer. Stop reuse of the old evidence until the technical effect of the change is understood.

Batch and order identification should connect the approved specification to manufacturing and shipment. The record does not need to claim that every order is a unique laboratory study, but it must show that the goods supplied match the assessed material and formulation set. When several sizes share an evidence file, document why the compliance-relevant construction is equivalent.

What HS PACKFACTORY Can Support

For a defined paper-packaging project, HS PACKFACTORY can help organise the commercial and manufacturing inputs that a buyer or responsible operator needs to assess. Availability depends on the selected materials, suppliers, order route and agreed evidence scope.

• paper or paperboard specifications and identified production revision;
• coating, lamination, ink and adhesive information where available;
• a component list linked to the dieline or approved construction;
• supplier declarations and relevant test reports where available and applicable;
• physical samples, dielines, artwork references and sample-approval records;
• order, batch or production identification and agreed change-notification coordination.

HS PACKFACTORY cannot issue EU regulatory approval, an official universal PFAS certificate, guaranteed Article 5 compliance, guaranteed PFAS-free status or legal sign-off for the responsible manufacturer or importer. The final conclusion depends on the actual package, evidence, market route and responsibilities of the relevant economic operators.

Official EU Sources

• Regulation (EU) 2025/40 on packaging and packaging waste — Article 5 and Annex VII.
• Commission Guidance C/2026/3084 — implementation interpretation and recommended analytical approach.
• European Commission PPWR FAQ — current Article 5 and supply-chain clarifications.
• Regulation (EC) No 1935/2004 — general food-contact materials and articles framework.
• Regulation (EC) No 1907/2006 (REACH) — chemical framework and role definitions referenced by Article 5.