PPWR — PFAS ban in food-contact packaging

PFAS are chemical substances used in the grease- and moisture-repellent coatings of many food packaging formats. You find them in fast-food boxes, baking papers, coated cardboard trays and microwaveable packaging. The list is longer than most packaging teams assume.

The most important and least understood legal point is the complete absence of a grace period. Unlike most regulatory transitions, there is no provision allowing non-compliant stock manufactured before 12 August 2026 to be sold through. A non-compliant pack cannot be placed on the market after that date, even if it has already been produced and is sitting in the warehouse. That is a direct and immediate financial risk for any business that has not yet audited its portfolio.

The Commission set out a three-tier testing methodology in its guidance of 30 March 2026: a total fluorine test first, with an indicative threshold of 50 ppm, then pyrolysis GC/MS if that threshold is exceeded, then TOP analysis for confirmation. This methodology is not legally prescriptive, but it has become the de facto reference for national-authority checks.