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From August 12, 2026, food-contact packaging placed on the EU market must meet specific PPWR PFAS concentration limits under the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40). The thresholds are precise, the data requirements are demanding, and the documentation burden falls directly on your supply chain as manufacturer.
This post covers the PPWR PFAS restrictions your team needs to prepare for, the supplier data you must secure, and how to structure your technical documentation before the deadline.
1. How the PPWR Defines PFAS
Before requesting supplier data, it is worth agreeing on exactly what the regulation targets. Under article 5 of the PPWR, PFAS is defined as any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, without any hydrogen, chlorine, bromine, or iodine attached to it.
The definition includes specific exceptions. If a substance only contains CF3-X or X-CF2-X’ groups, where X or X’ is a methyl, methylene, aromatic group, or carbonyl group, it may fall outside the restriction. Your packaging team should cross-reference the exact chemical structures of your materials against these exemptions before drawing conclusions.
2. The Three Critical PFAS Thresholds
Starting August 12, 2026, food-contact packaging cannot be placed on the market if PFAS concentrations meet or exceed any of the following limits:
- 25 ppb for any single PFAS, measured using targeted PFAS analysis. Polymeric PFAS are excluded from this quantification.
- 250 ppb for the sum of PFAS, measured as the sum of targeted PFAS analysis. Polymeric PFAS are also excluded here.
- 50 ppm for total PFAS. This threshold is broader: it includes polymeric PFAS.
The distinction between the first two thresholds and the third matters. Targeted analysis covers specific PFAS compounds. Total PFAS analysis is wider and will catch materials that appear compliant under targeted testing alone. Your technical documentation needs to address all three.
3. The “Total Fluorine” Trap
This is where many packaging teams run into difficulty, and it is worth understanding before you start collecting supplier data.
If a packaging material’s total fluorine content exceeds 50 mg/kg, you cannot assume compliance. At that point, the manufacturer, importer, or downstream user is legally required to demonstrate how much of that fluorine comes from PFAS and how much does not.
In practice, this means a standard material declaration from your supplier is not enough. You need documentation that differentiates between PFAS-sourced fluorine and non-PFAS fluorine, and that breakdown must form part of your Annex VII technical files. If a supplier cannot provide this, treat it as a procurement issue to resolve now.
4. Other Chemical Restrictions to Prepare For
PFAS is the most technically demanding restriction, but your compliance files must also cover two additional areas.
- Heavy metals: The combined concentration of lead, cadmium, mercury, and hexavalent chromium in packaging and its components cannot exceed 100 mg/kg. This threshold applies to the sum of all four metals, not to each individually.
- Bisphenol A (BPA): A comprehensive restriction on BPA applies across food packaging and food-contact materials. Factoring in the 18-month general transition period, managing BPA-free supply chains alongside the new PPWR chemical thresholds is a parallel compliance priority for 2026. If BPA has not yet been addressed in your technical documentation, it should be.
5. What to request from your suppliers
Your suppliers may not be accustomed to providing this level of chemical analysis, and some will need clear guidance on what is required. Here is the breakdown of what your technical files must contain for each food-contact material.
For PFAS:
- Targeted PFAS analysis results, listing individual PFAS compounds and concentrations in ppb
- Sum of PFAS concentrations, including results with prior precursor degradation where applicable
- Total PFAS measurement in ppm, covering polymeric PFAS
- Where total fluorine exceeds 50 mg/kg: a breakdown confirming the quantity of PFAS-sourced versus non-PFAS fluorine
For heavy metals:
- Declarations or test results showing combined lead, cadmium, mercury, and hexavalent chromium concentrations below 100 mg/kg
For BPA:
- Declaration of compliance according to Annex III of the Commission Regulation (EU) 2024/3190, confirming the BPA-free formulation, or documentation of BPA use within permissible limits.
Request these in a structured format that can be stored and retrieved as part of your formal technical documentation.
How PAQR can help
The PFAS documentation challenge is largely a data collection and organisation problem. Your suppliers need to know exactly what to send, you need a structured place to store it, and your technical files need to be complete and retrievable when an audit requires them.
PAQR’s supplier request portal lets you send targeted data requests directly to your suppliers, specifying exactly which declarations, test results, and certifications you need. Responses are stored centrally alongside the rest of your packaging data, so your PFAS declarations, heavy metal certifications, and BPA confirmations sit in the same auditable workspace as your component specs, recyclability assessments, and supplier certificates.
When you are ready to generate your Declaration of Conformity, the documentation you have collected feeds directly into the process.
Click “Try now for free” on paqr.com to start a free trial.
