PFAS in Food-Contact Packaging: the PPWR Limits and the Evidence You Need (2026)

On 12 August 2026 — the day the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) applies — packaging that comes into contact with food may no longer be placed on the EU market if it contains PFAS above set thresholds. It lands on the same day as the mandatory Declaration of Conformity, and there is no grace period for either. This guide covers what the limits are, who they catch, and the part many compliance tools underplay: what evidence you actually need behind the declaration.

The limits

Two practical notes. First, the total-fluorine figure works as a screen: if a fluorine measurement comes back above 50 ppm, you need to be able to show whether that fluorine is PFAS or something else. Second, these are concentrationthresholds in the packaging material — “we don’t intentionally add PFAS” is not the same claim as “measured below the thresholds,” because PFAS can arrive unintentionally via recycled content, coatings, or processing aids. The European Commission’s PPWR guidance (C/2026/3084) confirms the conformity route is self-assessment (Module A, Annex VII) — no notified body, which means the burden of having credible evidence sits entirely on you.

Who this catches

Anyone placing food-contact packaging on the EU market: the obvious cases (trays, wraps, cups, pouches, bakery papers — grease-resistant coatings are the classic PFAS risk) and the less obvious ones, like e-commerce packaging around food products. If you import, the obligation lands on you as the economic operator placing it on the market — which is why importers end up chasing their suppliers for exactly the evidence described below.

Declaration vs. evidence — the distinction that matters

Most compliance tools handle PFAS by collecting supplier declarations: a form where the supplier ticks “complies with PPWR Article 5.” Collecting those declarations is necessary — but the Declaration of Conformity you sign must be backed by technical documentation, and for a measurable limit, meaningful documentation is analytical: laboratory test reports or Certificates of Analysis (CoAs) showing measured values against the thresholds. If a market-surveillance authority asks why you believed the packaging was compliant, “the supplier said so” is a much weaker file than “here is the lab report, dated, with values under the limits.”

A useful CoA or test report shows: the material or item tested, the laboratory and method (targeted PFAS analysis and/or a total-fluorine screen), the test date, and the measured values. Currency matters — a three-year-old report for a material whose supplier has since changed coatings proves little, which is why treating substance evidence as something that expires and needs renewing is good practice.

How this flows into your Declaration of Conformity

The Annex VIII DoC declares conformity with the substance requirements among others — so the PFAS evidence is part of the technical file behind the signature. The clean workflow: gather the CoAs per packaging material, check the values against the thresholds, fix or substitute what fails, and only then draft and sign the DoC. (Fees and EPR registration are a separate obligation on a separate track — paying fees does not produce a DoC.)

How VerdLynx handles it

VerdLynx’s substances module works on the evidence layer, not just the declaration layer: upload the supplier’s CoA and the platform reads the document, extracts the measured values, and checks them against the PPWR thresholds — pass, marginal or fail, with the extracted evidence shown so you can verify the reading. Certificates carry test dates and expiry, reminders fire before they lapse, and the Declaration of Conformity drafting is gated on the substance check passing. The platform drafts; a human reviews and signs — VerdLynx doesn’t “guarantee compliance,” it makes the evidence checkable. For how this compares with other tools’ approaches, see the software comparison guide.

FAQ

What are the PPWR PFAS limits for food-contact packaging?

25 ppb for any single PFAS (targeted analysis), 250 ppb for the sum of targeted PFAS, and 50 ppm for PFAS in total (total organic fluorine), from 12 August 2026.

Is a supplier declaration enough?

Often not by itself — the technical documentation behind your DoC should include analytical evidence for measurable limits. Declarations plus test reports is the defensible combination.

When does the restriction apply?

12 August 2026, with no grace period.

What should the test report show?

Material tested, lab and method, test date, and measured values comparable against the three thresholds — recent enough to reflect the material you’re actually shipping.

Try VerdLynx free → 10 SKUs, no card needed · or start with the plain-English PPWR guide.

Thresholds and dates are drawn from Regulation (EU) 2025/40 and the European Commission’s PPWR guidance (C/2026/3084); verify the current text for your specific case. This guide is general information, not legal advice, and testing decisions should be made with your laboratory and advisors.