PFAS in food contact packaging: does "not intentionally added" make you compliant?

Summary

A declaration that PFAS is "not intentionally added" does not, on its own, make food contact packaging compliant under the PPWR. The PPWR PFAS restriction is a limit-value restriction based on the measured concentration of PFAS, not on whether PFAS was deliberately used. To demonstrate compliance you need evidence that the actual fluorine and PFAS levels sit below the legal limits. "Not intentionally added" is a useful risk signal that justifies a lighter testing route, but it is not a compliance route in itself.

A frequent assumption among brand owners and packaging manufacturers is: "If I declare that PFAS was not intentionally added, my packaging is directly compliant." This is incorrect and creates real compliance exposure. The sections below explain why, and set out the correct way of working.

PPWR Article 5 prohibits placing food contact packaging on the market where PFAS is present at or above these limit values:

• 25 ppb for any single PFAS, measured with targeted PFAS analysis (polymeric fraction excluded)
• 250 ppb for the sum of PFAS, measured as the sum of targeted PFAS analysis (optionally after degradation of precursors)
• 50 mg/kg for total PFAS including the polymeric fraction (assessed via total fluorine)

The restriction is triggered by the measured concentration. There is no exemption or safe harbour for PFAS that was "not intentionally added." The "intentionally added" concept belongs to other regimes (for example REACH-type restrictions and ESPR) and should not be carried over to the PPWR food contact rule.

PFAS frequently ends up in packaging without anyone adding it on purpose. Common routes include recycled feedstock, processing aids, inks and coatings, raw material impurities, and cross-contamination in the supply chain. Because the law measures what is present rather than what was intended, a "not intentionally added" statement cannot prove the material is below the limit values.

There is also no grandfathering. Packaging produced before 12 August 2026 may not be placed on the market after that date if it exceeds the limits, and authorities can request proof of fluorine content. A declaration of intent is not such proof.

Treat "not intentionally added" as an input that lowers the risk profile and reduces testing frequency, then establish the concentration evidence:

1. Confirm food contact applicability. If the packaging component is not in contact with food, the Article 5 PFAS restriction does not apply.
2. Screen for intentionally added PFAS. A "not intentionally added" answer lowers risk but does not close the assessment. It routes the component to screening, not to a compliant verdict.
3. Run total fluorine (TF) screening. This is the efficient first measurement. If total fluorine (or total organic fluorine) is below 50 mg/kg, the component can be treated as compliant and no targeted PFAS testing is needed. This is the legitimate way to avoid testing every component.
4. Resolve the fluorine profile where TF is above 50 mg/kg. Inorganic fluorine is not PFAS and can support a compliant outcome. An organic or mixed profile is escalated to targeted analysis.
5. Run targeted analysis (Direct TOP) against the limits where required, checking against 25 ppb (any PFAS), 250 ppb (sum) and 50 mg/kg (total including polymeric).
6. Keep the evidence. Retain supplier declarations backed by data, TF and TOF results, and any targeted results as the auditable proof of compliance.

This sequence is reflected in the SyncForce PFAS Compliance Assessment Flow, which routes every food contact component through a measured screening step before reaching a compliant, non-compliant or not applicable outcome, with the decision thresholds aligned to the Article 5 limit values. You can view the full flow here: https://synf.co/PFAS-assessment

How this works in SyncForce

In the SyncForce assessment, indicating "not intentionally added" does not auto-resolve the component as compliant. The model still requires a measured fluorine value, because PPWR compliance is concentration-based. This is by design and reflects the regulation correctly. Use the "not intentionally added" status to qualify the component for total fluorine screening, then rely on the measured TF result to confirm it sits under the 50 mg/kg threshold, escalating to targeted testing only where the screening or fluorine profile requires it.

Conclusion

Under the PPWR, "not intentionally added" is a risk-screening input, not a compliance conclusion. The regulation restricts PFAS by measured concentration, with no carve-out for unintentional presence and no grandfathering. Compliance is demonstrated by evidence that the fluorine and PFAS levels are below the Article 5 limits, obtained through total fluorine screening first and targeted analysis where needed, and supported by retained documentation. The SyncForce assessment flow is built on exactly this logic, which is why it asks for a measured value even when PFAS is declared as not intentionally added.