The latest European Commission FAQ confirms that PFAS limits apply to the whole packaging unit, including inks, varnishes and adhesives, without distinguishing between intentional addition and unintentional presence. The real challenge is not finding a single “fluorine-free” report, but establishing traceable testing, technical documentation and a complete evidence chain for alternatives.
BIOTEN Packaging | PPWR compliance observations
From 25 ppb and 250 ppb to 50 ppm: testing, evidence and alternatives for paper cups, food boxes, grease-resistant paper and molded fiber
The latest European Commission FAQ confirms that PFAS limits apply to the whole packaging unit, including inks, varnishes and adhesives, without distinguishing between intentional addition and unintentional presence. The real challenge is not finding a single “fluorine-free” report, but establishing traceable testing, technical documentation and a complete evidence chain for alternatives.
Three sets of limits: identify the substance being measured before comparing numbers.
25 ppb
Any individual PFAS measured by targeted analysis; polymeric PFAS are excluded from this quantification.
250 ppb
The sum of PFAS measured by targeted analysis; consider precursor degradation where applicable.
50 ppm
Includes polymeric PFAS; the substances covered differ from those covered by the first two limits.
The three limits cannot be compared simply by their numerical size. Exceeding any one cannot be offset by meeting the other two.
2026-08-12
5 days until the EU PFAS limits for food-contact packaging take effect.
From this date, food-contact packaging that reaches or exceeds any PFAS threshold specified by the EU PPWR must not be placed on the EU market.
Many companies first think:
“Our products are paper-based.”
“Our coatings are waterborne.”
“The supplier says no PFAS were intentionally added.”
“The base paper has already been tested.”
However, none of these statements alone is sufficient to demonstrate compliance of the final packaging.
The European Commission’s official PPWR FAQ, published on 2026-08-03, clarifies four points that industry can easily overlook (source 2):
01 This is not a general “total PFAS ban”, but three sets of maximum concentration limits.
02 The limits apply to the entire packaging unit, including inks, varnishes, glues and adhesives.
03 Intentionally added PFAS and unintentionally present PFAS are not treated differently.
04 The EU does not yet have a harmonized PFAS testing protocol.
What changes on August 12 is not just whether a particular grease-resistant agent can still be used, but the compliance approach for food paper packaging:
From “What materials did I use?” to “Can I prove that the entire package is within the limits?”
1. Clarify the scope: PPWR regulates the final food-contact packaging, not simply the paper.
Under PPWR Article 5(5), from 2026-08-12, food-contact packaging with PFAS concentrations reaching or exceeding any specified limit must not be placed on the market (source 1).
There are three key points.
1. Food-contact packaging
The three PFAS limits concern packaging intended to come into contact with food. They cannot simply be applied to all non-food paper boxes, transport boxes or industrial packaging.
From the same date, other packaging may still be subject to general PPWR requirements concerning substances of concern and heavy metals. Those obligations must be distinguished from the PFAS concentration limits for food-contact packaging.
2. Reaching or exceeding the limit
The regulation uses “reaching or exceeding” the limits. The values of 25 ppb, 250 ppb and 50 ppm are market-access boundaries, not targets to approach without a safety margin.
Laboratory detection limits, measurement uncertainty, sample homogeneity and batch variation should inform internal risk margins before test results approach a regulatory limit.
3. The whole packaging unit
The latest European Commission FAQ further clarifies that the limits apply to the entire packaging unit, including (source 2):
Base paper or paperboard;
Functional coatings for grease resistance, water resistance or heat sealing;
Inks and varnishes on internal and external surfaces;
Glues and adhesives;
Other components integrated into the packaging.
Compliant base paper does not automatically make a food box compliant. A waterborne barrier coating with no intentionally added PFAS does not establish compliance of the final printed, varnished and glued packaging.
The regulation addresses the final packaging, while companies often hold evidence for only a single material. This mismatch is a major evidence gap.
2. What do the three thresholds assess?
The three PPWR thresholds differ in the substances covered, not just their numerical values.
Limit 01
25 ppb
First threshold: any individual PFAS measured by targeted analysis
If targeted analysis measures any individual PFAS at or above 25 ppb, the packaging must not be placed on the market.
Polymeric PFAS are excluded from quantification under this threshold.
The question is whether any individual targeted PFAS exceeds the limit. A report’s value therefore depends on its target substances, pretreatment and detection limits, not simply a “not detected” statement on its cover.
Limit 02
250 ppb
Second threshold: the sum of PFAS measured by targeted analysis
If the sum of PFAS measured by targeted analysis reaches or exceeds 250 ppb, the packaging must likewise not be placed on the market.
Where applicable, results following precursor degradation must also be considered. Polymeric PFAS are excluded from quantification under this threshold.
This threshold addresses cases where individual substances are below 25 ppb but their cumulative total remains high.
Limit 03
50 ppm
Third threshold: PFAS including polymeric PFAS
The third threshold is 50 ppm and explicitly includes polymeric PFAS.
Numerically, 50 ppm equals 50,000 ppb. Although much higher than the first two values, it is not a more permissive threshold: it covers a different range of PFAS, including polymeric PFAS.
These are three different risk perspectives:
25 ppb: individual targeted substances;
250 ppb: the cumulative total of targeted substances;
50 ppm: a broader scope that includes polymeric PFAS.
Reaching any threshold cannot be offset by remaining below the other two.
3. The frequently misunderstood “fourth number”: total fluorine of 50 mg/kg
The regulation also refers to another value that can be confused with the third threshold: total fluorine exceeding 50 mg/kg.
For solid samples, 50 mg/kg numerically equals 50 ppm. However, the two values of “50” measure different things:
The 50 ppm limit concerns PFAS mass, including polymeric PFAS;
50 mg/kg concerns the total fluorine in the sample.
Fluorine may originate from PFAS or non-PFAS fluorinated substances. Total fluorine results cannot be directly converted into “total PFAS”.
Under PPWR, where total fluorine exceeds 50 mg/kg, the relevant manufacturer, importer or downstream user must, upon request, provide evidence of whether the fluorine comes from PFAS or non-PFAS substances to support technical documentation.
The correct interpretation is therefore:
Total fluorine above 50 mg/kg triggers further explanation and evidence; it does not automatically establish product non-compliance.
Conversely, total fluorine below 50 mg/kg does not alone prove that all three PFAS limits are met. A sample with a low total fluorine screening signal may still reach the 25 ppb individual threshold or the 250 ppb sum threshold.
Instead of asking “Can we choose either total fluorine testing or targeted PFAS testing?”, companies should ask:
Which risks does each method cover, and how can the methods form an explainable evidence chain?
4. What should companies do without a CAS list or harmonized testing protocol?
The latest European Commission FAQ provides two important practical answers (source 2).
First, no finite PFAS CAS list will be published.
PPWR uses a structural definition. Substances meeting that definition that may be present in packaging can fall within scope.
Testing a fixed list demonstrates coverage of that list, not automatically of all PFAS. Target selection must reflect formulations, impurities, historical uses, supply-chain information and production risks.
Second, there is currently no harmonized EU testing protocol.
The European Commission says it is working with stakeholders, competent authorities and the EU reference laboratory for food-contact materials on harmonization.
Until a harmonized protocol is available, testing remains possible, but results must be understood within the limits of each method:
Is the sample base paper, a coating, an individual component or final packaging?
Which PFAS are included in the target list?
Are relevant precursors covered or appropriately treated?
How are polymeric PFAS assessed?
What pretreatment and reporting methods are used for total fluorine or total organic fluorine?
What are the detection limits, quantification limits and measurement uncertainties?
Which SKU, formulation version, batch and production date does the sample represent?
Without these answers, a “PFAS not detected” report is unlikely to support continued release of the final packaging.
5. Paper packaging risks differ: prioritize checks using four variables.
The law does not publish an official risk ranking for paper cups, food boxes, grease-resistant paper and molded fiber, or establish PFAS content solely from a product-category name.
Companies can nevertheless prioritize checks using four variables:
Variable one: functional demands
Must the packaging withstand grease, moisture, hot food, prolonged contact or high-temperature processing? Greater functional demands warrant closer scrutiny of historical formulations and alternative routes.
Variable two: historical chemicals
Has the supplier used fluorinated grease-resistant agents, fluorinated processing aids or an unexplained high-level grease-resistant system? Has the old formulation been explicitly discontinued, or is there only a verbal commitment?
Variable three: structural complexity
Unprinted grease-resistant paper differs substantially from a coated, printed, varnished, die-cut and glued food box. More components create more potential unknown sources and cross-contamination pathways.
Variable four: evidence completeness
Can evidence be traced to the exact SKU, batch, formulation version and supplier changes? Is there final-packaging testing? Does the declaration cover unintentional presence as well as intentional addition?
Historical uses and functional demands suggest prioritizing the following products in internal risk inventories:
Fast-food wrapping paper, burger wraps and highly grease-resistant paper;
High-barrier paper bags such as microwave popcorn and pet-food bags;
Takeaway paperboard food boxes, paper bowls and containers for hot, oily food;
Baking paper, liners and other grease- and heat-resistant papers;
Molded pulp plates, food boxes and food trays;
Paper cups and food containers with printing, varnishes, adhesives or composite structures.
US FDA historical information confirms that PFAS-containing grease-resistant substances were used in fast-food wrapping paper, microwave popcorn bags, takeaway paperboard containers and pet-food bags (source 4). This helps prioritize risk checks but does not prove that a particular product today contains PFAS.
The appropriate approach is to establish a risk record for each final structure rather than label an entire product category.
6. A practical five-layer evidence framework
Because a harmonized EU testing protocol is not yet available, the following is a company risk-control framework, not an “official EU five-step method”.
Layer one: BOM and supply-chain declarations
Break down the final packaging into base paper, coatings, inks, varnishes, adhesives, additives, composite layers and integrated components, without omitting any component.
Supplier documents should identify at least:
The exact product name, SKU and formulation version;
Whether PFAS meeting the PPWR structural definition are intentionally used;
Known risks from impurities, cross-contamination and processing aids;
The plants, batches and validity periods covered;
How formulation, raw-material or process changes are notified.
“No intentionally added PFAS” can support risk identification but cannot independently establish final compliance.
Layer two: total fluorine or total organic fluorine screening
Screening can quickly identify potential discrepancies between supply-chain declarations and actual samples and help prioritize further testing.
Screening cannot automatically identify specific PFAS or independently replace targeted assessment against the 25 ppb and 250 ppb limits.
Layer 3: targeted PFAS analysis and necessary precursor assessment
Targeted analysis should cover substances relevant to formulations, uses and historical risks. Reports should list targets, methods, detection limits and quantification limits.
Where precursor conversion is a risk, confirm appropriate treatment and reporting with laboratories, EU customers or importers.
Layer 4: cross-checking final packaging and critical components
Final-packaging testing asks whether the market object meets the limits overall; component testing identifies the source of risk and the layer requiring change. These serve different diagnostic and release purposes.
For printed food boxes, composite paper bags and molded fiber tableware, identify at least:
Unprocessed base materials;
Functional coatings or liners;
Final packaging after printing, varnishing and gluing;
Worst-case colors, coverage, coat weights or adhesive quantities;
Normal production batches and representative batches after formulation changes.
Layer 5: technical documentation, declarations of conformity and change control
PPWR Annex VII technical documentation should form a reviewable evidence chain rather than a collection of unrelated reports, including (source 1):
A general description of the packaging and its intended use;
Design, component and material information;
Analysis and assessment of non-compliance risks;
Standards, technical specifications or alternative solutions used;
Qualitative assessments and test reports;
Controls ensuring consistency in series production;
The EU declaration of conformity and subsequent updates.
Relevant technical documentation and declarations of conformity are normally retained for 5 years for single-use packaging and 10 years for reusable packaging.
A defensible evidence chain connects declarations, testing, structures, batches and changes.
7. Suppliers, manufacturers and importers: who carries the evidence chain?
First establish the legal role in the specific transaction. Brand ownership, the name or trademark used to place packaging on the market, design and ordering responsibilities can affect that role.
Under the PPWR responsibility framework:
Suppliers
Provide manufacturers with the information and documents needed to demonstrate compliance of packaging and packaging materials. Requests for exact SKUs, formulation declarations, test methods and change records are more than additional paperwork.
Manufacturers
Complete conformity assessment, establish technical documentation and issue an EU declaration of conformity before placing packaging on the market; ensure that series production remains consistent with that documentation.
Importers
Place only compliant packaging on the EU market, verify that assessments, documents and declarations are complete, and stop placement where there is reason to suspect non-compliance.
For Chinese papermaking, coating, printing and packaging companies, this means:
EU customers’ evidence requests will continue upstream. Structured data can support entry into qualified supply chains; a bare “PFAS-free” claim may leave a gap in the evidence chain.
8. Replacing PFAS requires more than a new marketing phrase.
Companies evaluating waterborne barriers, bio-based coatings or PHA as non-fluorinated candidate routes should address four areas of validation together.
1. Chemistry and compliance
Assess PFAS risks, impurities and cross-contamination across formulations and components; verify the three concentration boundaries on final packaging and establish food-contact migration and safety evidence.
2. Functional performance
Grease resistance is only a starting point. Evaluate real foods and use conditions, including:
Hot oils, room-temperature fats and prolonged contact;
Water absorption, leakage and water-vapor barriers;
Barrier continuity after folding, creasing, die cutting and pinholes;
Heat-seal initiation temperature, seal strength and sealing windows;
Target uses such as microwave heating, baking, refrigeration or freezing.
3. Processing stability
Successful laboratory coating does not establish stable operation on paper machines, coaters, printing presses or forming lines. Validate solids, viscosity, drying load, foaming, roll sticking, print registration, friction coefficient, die-cut dusting and line speed on representative equipment.
4. Recycling and system outcomes
Paper-based does not automatically mean recyclable. Consider coat weight, fiber separation, screening rejects, adhesive residues and compatibility with local recycling systems alongside barrier performance.
A mature alternative route must therefore answer all of these questions:
Does it meet the regulatory limits? Withstand real foods? Run on industrial lines? Fit the target recycling system?
Without all four answers, it remains a material concept rather than a scalable packaging solution.
9. With only 5 days remaining, what can companies do now?
Five days may not be enough to complete every laboratory test and formulation change, but can be enough to move risks from unknown to manageable.
0–8 HOURS
Build an inventory based on final structures, not category names.
List all food-contact packaging SKUs intended for the EU market;
Record final structures, uses, food types, temperatures and contact times;
Identify supplier, manufacturer, brand-owner and importer roles;
Review produced goods, goods in transit, stock and placement plans after August 12.
8–24 HOURS
Collect documents and lock formulation versions.
Request exact-SKU declarations from base-paper, coating, ink, varnish and adhesive suppliers;
Check the definition and scope of “not intentionally added” declarations;
Collect sample details, methods, targets and detection limits from existing reports;
Pause unrecorded formulation, raw-material and process changes.
24–48 HOURS
Classify risks and define samples and methods.
Divide SKUs into three categories:
Red
Unknown historical chemicals, missing supplier documents, insufficient testing scope or an unverified final structure;
Yellow
Some declarations and tests exist, but component, batch or method gaps remain;
Green
A complete BOM, traceable evidence, and connected final-structure and batch controls.
Agree sample objects, target lists, screening methods, precursor assessments, detection limits and reporting with laboratories, customers or importers so that results can be understood consistently.
48–72 HOURS
Make release decisions and stop unknown risks from continuing downstream.
Place red SKUs on HOLD; do not substitute “nothing found so far” for evidence;
List gaps, owners and closure dates for yellow SKUs;
Create technical-document indexes and customer delivery packages for green SKUs;
Begin small-scale trials, production-line validation and final-packaging retesting for structures requiring replacement;
Include supplier change notifications and reassessment triggers in the quality system.
The priority is not creating a complete-looking file within five days, but ensuring that every SKU released after August 12 has sufficient supporting evidence.
10. A readiness checklist: is your product prepared?
Before releasing food paper packaging for the EU market, answer these 10 questions:
01 Have we established the legal role and who places the packaging on the market?
02 Does the final-packaging BOM cover base paper, coatings, inks, varnishes, adhesives and all components?
03 Does each declaration identify the exact SKU, plant, formulation version and batch?
04 Beyond intentional addition, have impurities, processing aids and cross-contamination been assessed?
05 Are the test samples single materials or final packaging units?
06 Does the targeted PFAS report identify targets, methods, detection limits and quantification limits?
07 Has total fluorine screening been interpreted correctly rather than presented as “PFAS-free” proof?
08 Have polymeric PFAS and relevant precursor risks been considered?
09 Do technical documents connect risk assessment, test reports, series production and the EU declaration of conformity?
10 Do formulation, raw-material, process or supplier changes trigger reassessment?
An unanswered critical question creates uncertainty about continued market access, not simply an imperfect document.
Conclusion: August 12 ends reliance on material descriptions as substitutes for compliance evidence.
Paper-based, waterborne, bio-based, fluorine-free and environmentally friendly describe technical directions; they do not complete conformity assessment for final packaging.
PPWR returns companies to a more rigorous and practical starting point:
The material used is only the first question. Its performance in final packaging, testing coverage and traceable evidence determine market access.
For papermakers, this means chemical and batch management;
For coating, ink and adhesive companies, exact-SKU and formulation evidence;
For printers and packaging converters, a complete BOM and final-structure validation;
For food brands and importers, supply-chain release and continued compliance.
August 12 is not the end of every fluorinated-chemical issue.
It is a dividing line after which food paper packaging cannot enter the EU market on the basis of “it should be fine”.
What matters is not simply a “PFAS-free” phrase, but a defensible evidence chain that can be kept up to date.
Sources and scope
This article reflects information available as of 2026-08-07 and prioritizes EU legislation and the latest European Commission implementation FAQ. The five-layer evidence framework, four-variable prioritization and 72-hour action plan are BIOTEN Packaging’s company risk-management frameworks, not a harmonized Commission testing protocol or a substitute for product-specific legal, laboratory or compliance advice.
Regulation (EU) 2025/40 — EUR-Lex official text: Article 5(5–6), Articles 15–16 and 38–39, and Annex VII.
European Commission — PPWR Frequently Asked Questions, published 2026-08-03: see PFAS and supply-chain documentation questions.
European Commission — Packaging and Packaging Waste: general application dates and implementation information.
U.S. FDA — PFAS Used in Grease-Proofing Agents for Food Packaging: historical uses and withdrawal background for PFAS grease-proofing agents in paper and paperboard food packaging.
Join the discussion.
Where does your product currently face a bottleneck: supplier declarations, testing methods, final-packaging validation or production-line performance of alternative materials? Share your questions as we continue examining technical issues in the PFAS evidence chain.
