PPWR PFAS Limits: What is actually required

Since 12 August 2026, food-contact packaging that contains PFAS at or above the limits in Article 5(5) of Regulation (EU) 2025/40 may no longer be placed on the EU market. Most summaries describe this as a restriction on "intentionally added" PFAS. Those two words do not appear in the Article. That gap changes what a packaging team has to prove.

The Regulation regulates presence, whatever its source

Article 5(5) states that food-contact packaging shall not be placed on the market if it contains PFAS in a concentration equal to or above the limit values. The test is presence and concentration. How the PFAS got there does not enter the calculation. Intent may matter in a commercial dispute with a supplier. The test a market surveillance authority applies is the one in the Regulation: presence and concentration.

Fluorinated processing aids on a paper machine, contamination carried in recycled fibre, a grease-resistant coating applied by a sub-supplier two tiers down: each case counts the same way. The packaging either contains PFAS below the limits, or it does not.

The same paragraph defines PFAS structurally, by fully fluorinated carbon atoms, with a short list of structural exceptions. The Commission's PPWR FAQ (second edition, August 2026) confirms that no list of PFAS substances will be published. A supplier who "checked against the list" has not checked what Article 5(5) asks for. The FAQ is guidance rather than law, but on this point it restates what the structural definition already implies.

Three limits, and one number that is not a limit

The Regulation sets three thresholds:

• 25 ppb for any single PFAS, measured with targeted analysis, polymeric PFAS excluded from quantification (Article 5(5), point (a)).
• 250 ppb for the sum of PFAS, measured as the sum of targeted analysis, where applicable with prior degradation of precursors, polymeric PFAS excluded (Article 5(5), point (b)).
• 50 ppm for PFASs including polymeric PFAS (Article 5(5), point (c)).

All three are "equal to or above" limits. Packaging at exactly 25 ppb is caught.

A fourth number circulates in most guides: 50 mg/kg total fluorine. It also appears in Article 5(5), point (c), and it works as a documentation trigger. Where total fluorine exceeds 50 mg/kg, the chemical supplier, meaning the REACH manufacturer, importer or downstream user, must upon request give the packaging manufacturer or importer proof of how much of that fluorine is PFAS and how much is non-PFAS, so that the technical documentation under Annex VII can be drawn up. That specific proof duty rests on the chemical supplier in its REACH role; the duties of packaging and material suppliers run through Article 16. Total fluorine above 50 mg/kg leaves the packaging compliant as long as the three PFAS limits are met. It also obliges the file to explain the fluorine.

What this means for the technical file

Article 5(6) requires compliance with the substance limits to be demonstrated in the technical documentation. Article 16(1) obliges suppliers of packaging and packaging materials to give the manufacturer the information and documentation needed for that file. Read together, the two provisions turn PFAS from a purchasing question into a documentation question. The question moves from "did our supplier add PFAS?" to "what evidence do we hold that PFAS is below all three limits in this material, from this supplier, for this application?"

The answer differs by material. For a paper cup with a barrier coating, the evidence is a test report. For a glass jar with a metal closure, the file needs the liner compound supplier's data. For a mono-material polyethylene pouch from a known resin grade with no fluorochemical history, a documented risk assessment plus a knowledge-based supplier confirmation may be enough. The level of evidence follows the risk of the material, and the file records why.

What to test, and what to skip

Commission Notice C/2026/3084 (point 5, non-binding) recommends a three-step analytical approach, and PSL's contribution is the portfolio triage and the evidence model around it. The recommended sequence:

1. Screen total fluorine. Where the result stays below 50 mg/kg, the Notice says the sample could be considered compliant; record the result, the sampling basis and why no further analysis is needed.
2. Above 50 mg/kg, differentiate organic from inorganic fluorine. Inorganic fluoride from mineral fillers is a common source of false alarms.
3. Where the earlier steps do not resolve compliance, run direct targeted analysis, direct TOP analysis in the Notice's terms, for the 25 ppb and 250 ppb limits, with precursor degradation where the 250 ppb sum requires it. Material and coating history guides sampling and prioritisation; it does not replace the analytical sequence.

PSL's implementation layer on top of that sequence: testing every SKU is the expensive way to remain uncertain. A portfolio triage by material family and supplier, with sampling concentrated on coated fibre, fluoropolymer-containing components and any material with unexplained fluorine, covers the risk at a fraction of the cost, provided the analytical sequence itself is respected wherever compliance stays unresolved.

Key takeaways

• Article 5(5) applies to PFAS present in food-contact packaging at or above the limits, whatever the origin.
• Three limits apply: 25 ppb for a single PFAS, 250 ppb for the sum, 50 ppm including polymeric PFAS. All are "at or above".
• 50 mg/kg total fluorine is a documentation trigger. The chemical supplier must explain the fluorine on request.
• No PFAS list is coming. The definition is structural.
• Evidence level should follow material risk, and the Annex VII file should record the reasoning.

The PFAS limits are the most technical of the August 2026 requirements, and the ones where supplier paperwork most often falls short of what the file needs. If your team is working through PFAS evidence across a portfolio, PSL can help you decide what to test, what to document, and what to close on reasoning. Book a call with us to start the conversation.

This article distinguishes binding PPWR requirements from non-binding Commission guidance and from PSL's implementation approach. It is general information rather than legal advice for a specific packaging format, transaction or Member State.

PSL’s PPWR documentation and evidence support helps teams map their packaging, identify information gaps and prepare focused requests for suppliers.