PPWR PFAS and Chemicals in Packaging Compliance

PFAS and Chemicals in Packaging under PPWR

The EU’s Packaging and Packaging Waste Regulation (PPWR) is not only a packaging and waste regulation. It also introduces important requirements relating to substances in packaging.

One of the most immediate is the restriction on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging.

Since 12 August 2026, food-contact packaging containing PFAS at or above specified concentration limits cannot be placed on the EU market, subject to the applicable provisions of EU law.

For organisations using or supplying food-contact packaging, this creates questions around applicability, packaging composition, supplier information, testing and the evidence needed to support compliance.

 

PFAS limits under PPWR

PPWR establishes concentration limits for PFAS in food-contact packaging.

The Regulation specifies limits based on targeted PFAS analysis, the sum of targeted PFAS and total PFAS, with particular provisions concerning polymeric PFAS and total fluorine.

Understanding whether packaging complies can therefore require more than simply asking whether PFAS have intentionally been used.

Organisations may need to understand the materials used, information available from suppliers, the analytical approach and how results should be interpreted against the regulatory requirements.

 

Which packaging is affected?

The PPWR restriction relates specifically to food-contact packaging.

Determining whether the requirements apply can therefore involve considering both the packaging and its intended use.

For businesses with large packaging portfolios, an initial screening exercise can help identify potentially relevant packaging and prioritise where further information or investigation may be required.

This can include consideration of:

  • food-contact status;
  • packaging materials and components;
  • coatings and surface treatments;
  • available composition information;
  • supplier declarations;
  • existing analytical data; and
  • potential information gaps.

 

Evidence and testing

PFAS compliance presents a particular evidence challenge because information about the chemical composition of packaging may sit at different points in the supply chain.

Testing may form part of the evidence available to an organisation, but analytical results need to be considered in the context of the PPWR requirements and the limitations of the methods used.

The European Commission has published guidance addressing the enforcement of the PFAS restrictions, including a recommended stepwise approach. However, there is not currently a single harmonised EU analytical method established specifically for demonstrating compliance with the PPWR PFAS limits.

Organisations therefore need to consider carefully what evidence is proportionate and how supplier information and analytical evidence work together.

 

Working with packaging suppliers

For many businesses, direct knowledge of the chemical composition of packaging will be limited.

Supplier engagement can therefore be an important part of compliance.

Organisations may need to establish:

  • what information suppliers already hold;
  • whether suppliers can provide appropriate declarations or supporting evidence;
  • which packaging or materials require further investigation;
  • whether analytical testing is appropriate; and
  • how information will be maintained where materials or suppliers change.

A structured approach can help focus resources on areas where additional evidence is genuinely needed.

 

Chemicals considerations beyond PFAS

PPWR also contains broader provisions concerning substances in packaging.

The Regulation interacts with an existing framework of EU chemicals and product legislation, including REACH and legislation relating to food-contact materials.

This makes it important to consider PPWR requirements within the wider regulatory context rather than treating packaging substances as an isolated compliance issue.

For organisations managing both chemicals and product-regulatory responsibilities, this can create opportunities to align information gathering and compliance processes across different regulatory requirements.

 

How RPA can support organisations

RPA combines chemicals and product-regulatory expertise with understanding of the wider PPWR framework.

Our support can include:

Applicability assessment

Assessing whether particular packaging falls within relevant PPWR substances requirements.

PFAS compliance assessment

Helping organisations understand the PPWR PFAS limits and assess available information against the regulatory requirements.

Evidence strategy

Reviewing supplier information, existing data and evidence gaps to help determine a proportionate approach to demonstrating compliance.

Testing considerations

Supporting organisations in considering whether testing is appropriate and interpreting analytical approaches within the regulatory context.

Supplier information

Helping identify information that may need to be requested from packaging and material suppliers.

Wider chemicals regulation

Considering PPWR alongside relevant chemicals and product legislation where requirements interact.

A proportionate approach to PFAS compliance

The appropriate compliance approach will depend on the packaging, materials, available supplier information and existing evidence.

For some packaging, sufficient information may already be available. In other cases, further supplier engagement, investigation or analytical work may be appropriate.

RPA can help organisations develop an evidence-led approach based on the regulatory requirements and the characteristics of their packaging portfolio.

 

Speak to RPA about PFAS in packaging

If you need to understand how PPWR PFAS requirements affect your food-contact packaging, RPA can help you assess applicability, review available evidence and identify proportionate next steps.