PFAS restriction in food-contact packaging

The regulation explains that PFAS are highly persistent, can degrade into very persistent PFAS, and therefore represent an environmental and human health hazard. For that reason, PPWR introduces a restriction for PFAS in food-contact packaging.

A very important point for non-chemists is this: in PFAS testing, organic does not mean “better” or “more natural” like in food. Here, organic fluorine means fluorine attached to carbon-based chemistry, which is exactly the chemistry where PFAS lives. Inorganic fluorine means fluorine is present in a non-PFAS form. That is why, in the PFAS assessment logic, organic fluorine is the potentially problematic part and inorganic fluorine is the less relevant part for the PFAS threshold route. 

PPWR introduces a PFAS restriction for food-contact packaging from 12 August 2026. This restriction is implemented through maximum concentration levels in Article 5(5), not through a blanket PFAS ban. The legal thresholds are 25 ppb for any PFAS, 250 ppb for the sum of PFAS, and 50 ppm for PFAS including polymeric PFAS. Where Total Fluorine exceeds 50 mg/kg, the manufacturer must be able to demonstrate whether that fluorine is attributable to PFAS or non-PFAS sources.

The Commission guidance recommends a stepwise enforcement approach: first Total Fluorine screening, then confirmation whether fluorine is organic or inorganic, and then Direct TOP analysis to assess the lower PFAS thresholds. In this logic, organic fluorine is the relevant fraction because PFAS are organic fluorinated chemistry, while inorganic fluorine is not the PFAS-relevant fraction.

TF is the quick screening method.
It measures the total amount of fluorine in the packaging sample. It does not tell you which PFAS substances are there. It is basically a first check: “is there enough fluorine present to worry about PFAS?” The Commission guidance says that if TF is below 50 mg/kg, the sample could be considered compliant. If TF is above 50 mg/kg, follow-up is needed.

Direct TOP is the deeper PFAS method.
It is used to check compliance with the lower PPWR PFAS thresholds, especially 25 µg/kg for any PFAS and 250 µg/kg for the sum of PFAS. The Commission guidance describes Direct TOP as step 3 in the recommended enforcement approach.

Assessment logic in SyncForce

Assessment entry route

1. Product Contact Class

If product contact class of a packaging element is FOOD then PFAS restriction becomes applicable (in all other situation PFAS restriction is not-applicable.

2. Intentionally added

• Unknown (Default value)

• No 

• Yes, this will auto set the Assessment entry route to "Direct Top"

3. Assessment entry route

• TF Screening
• Direct TOP

The Commission guidance recommends a stepwise route starting with TF and then using Direct TOP, but iit does not say TF is legally mandatory as the only entry point. It says Direct TOP is recommended to check compliance with the 25 µg/kg and 250 µg/kg limits.

Route A: TF Screening

Use when you start with the 50 ppm route and only go deeper if needed.

Route B: Direct TOP

Use when you go directly to the lower-threshold PFAS testing route, for example because:

• customer policy requires it
• risk profile is higher
• lab or supplier already works with TOP
• a Mixed or Organic result requires deeper confirmation

2. Legal PFAS thresholds under Article 5(5)

From 12 August 2026, food-contact packaging may not be placed on the market if it contains PFAS at or above these levels:

• 25 ppb for any PFAS by targeted PFAS analysis
• 250 ppb for the sum of PFAS by targeted PFAS analysis, where applicable with prior degradation of precursors
• 50 ppm for PFAS including polymeric PFAS; if total fluorine exceeds 50 mg/kg, proof must be provided of fluorine measured as PFAS or non-PFAS.