Introduction
If you are sourcing paper cups, paper bowls, sandwich wrap paper, baking paper, PE coated paper, or other food packaging materials, you’ve probably heard more and more customers asking the same question:
“Is your packaging PPWR compliant?” “Is it PFAS Free?”
Since the EU adopted the Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40), PFAS has become one of the hottest topics in the packaging industry.
However, after reviewing numerous laboratory reports and discussing with third-party testing laboratories, I realized that there are still many misunderstandings about PPWR and PFAS testing.
This article explains the regulation in a practical and easy-to-understand way.
What is PPWR?
PPWR stands for Packaging and Packaging Waste Regulation (EU) 2025/40.
Unlike the previous Packaging Directive, PPWR is a Regulation, meaning it applies directly across all EU Member States.
Its objectives include:
- Reducing packaging waste
- Improving recyclability
- Restricting hazardous substances
- Increasing recycled content
- Supporting the circular economy
For manufacturers of food contact packaging, one of the biggest changes is the introduction of PFAS restrictions.
The PFAS requirement for food-contact packaging takes effect on 12 August 2026.
What are PFAS?
PFAS stands for Per- and Polyfluoroalkyl Substances.
These are a large family of fluorinated chemicals widely used because they provide:
- Oil resistance
- Water resistance
- Heat resistance
- Chemical stability
Historically, PFAS have been used in:
- Greaseproof paper
- Fast-food wrappers
- Microwave popcorn bags
- Baking paper
- Mold release coatings
- Industrial coatings
However, many PFAS compounds are extremely persistent in the environment, earning the nickname: “Forever Chemicals.”
As a result, regulators worldwide are gradually restricting their use.
PPWR PFAS Limits
For food-contact packaging, PPWR introduces three different limits.
| Requirement | Limit |
|---|---|
| Individual targeted PFAS | 25 μg/kg |
| Sum of targeted PFAS | 250 μg/kg |
| PFAS including polymeric PFAS | 50 mg/kg |
Many people only know about the 50 mg/kg requirement. In reality, all three limits must be considered together.
The Biggest Misunderstanding: Total Fluorine ≠ PFAS
This is probably the most misunderstood topic.
Many people think: Total Fluorine > 50 mg/kg = Product fails.
This is NOT entirely correct.
Total fluorine is only a screening tool. It measures all fluorine present in the sample, including:
- PFAS
- Polymeric PFAS
- Organic fluorinated compounds
- Inorganic fluorides
- Other fluorine-containing substances
Therefore, high total fluorine does not automatically mean high PFAS. Instead, it indicates that additional investigation may be required.
Why Do Some Reports Show PASS Even When Total Fluorine Exceeds 50 mg/kg?
This is another common question.
A laboratory report may show:
- Total Fluorine = 120 mg/kg
- 178 targeted PFAS = Not Detected
- Conclusion = PASS (for targeted PFAS)
This is because: The targeted PFAS analysis and the total fluorine screening are different tests.
A product can have very low targeted PFAS but relatively high total fluorine. This does not necessarily mean that PFAS exceeds the legal limit. It simply means that the fluorine source has not yet been fully identified.
Organic Fluorine Matters
According to the latest technical guidance, laboratories may use a step-by-step approach.
Typical workflow:
- Measure Total Fluorine
- If Total Fluorine is below 50 mg/kg, the product is generally considered to meet the screening requirement.
- If Total Fluorine exceeds 50 mg/kg, proceed to Step 2.
- Measure Total Organic Fluorine (TOF) This helps distinguish whether fluorine comes from:
- Organic fluorine
- Inorganic fluorine
If organic fluorine remains below 50 mg/kg, the product may still demonstrate compliance.
Why 178 PFAS Compounds Are Still Not Everything
Many laboratories now offer:
- 72 PFAS
- 128 PFAS
- 178 PFAS
At first glance, 178 compounds sounds comprehensive.
However, PFAS is not a list of only 178 chemicals. It is a very large chemical family with thousands of substances, including polymeric PFAS and precursors.
Therefore, a report showing “178 PFAS Not Detected” does not necessarily mean “PFAS Free.” This distinction is extremely important.
What Should Buyers Ask Suppliers?
Instead of asking only: “Do you have a PFAS Free Certificate?”
Consider asking:
- ✅ Which regulation does the report reference?
- ✅ Does it include targeted PFAS analysis?
- ✅ Does it include total fluorine?
- ✅ Was total organic fluorine evaluated if necessary?
- ✅ Which laboratory performed the testing?
- ✅ Is the report traceable to the actual production batch?
What Should Manufacturers Prepare?
As the PPWR implementation date approaches, manufacturers should prepare:
- Updated laboratory reports
- Product traceability
- Material specifications
- Technical documentation
- Food contact compliance documents
- Supplier declarations
- Quality control records
Compliance is no longer based on one single certificate. It is becoming a complete technical documentation system.
Final Thoughts
PPWR is changing the way the packaging industry evaluates food-contact materials.
For manufacturers, traders, converters and importers, understanding the difference between:
- Total Fluorine
- Organic Fluorine
- Targeted PFAS
- Polymeric PFAS
will become increasingly important.
The goal is not simply to collect more test reports. The goal is to understand what each report actually proves—and what it does not.
As laboratories continue to refine testing methods and regulatory guidance evolves, staying informed will help businesses make better sourcing decisions and prepare for future compliance requirements.
