PPWR : PFAS Limits for Food Packaging

October 28, 2026

PPWR : PFAS Limits and Evidence

PFAS Concentrations for Food Packaging

Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation,has applied since 12 August 2026, including its PFAS concentration limits for food-contact packaging.

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The limits are:

•     25 ppb for any PFAS measured using targeted PFAS analysis, excluding polymeric PFAS from quantification.

•     250 ppb for the sum of PFAS measured using targeted PFAS analysis, where applicable following prior degradation of precursors, excluding polymeric PFAS from quantification.

•     50 ppm for PFAS, including polymeric PFAS.

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Where total fluorine exceeds 50 mg/kg, the regulation requires the relevant manufacturer, importer or downstream user, upon request, to provide evidence concerning the quantity of fluorine attributable to PFAS or non-PFAS substances for the required technical documentation.

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The European Commission's PPWR guidance recommends a stepwise approach for food-contact packaging: initial total-fluorine screening; if total fluorine exceeds 50 mg/kg, further analysis to distinguish organic from inorganic fluorine; and direct TOP (total oxidizable precursors) analysis at step three to check compliance with the 25 ppb and 250 ppb limits. The guidance supports implementation but does not replace the binding regulation.

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NOTE : The scope is specific to food-contact packaging, not electronics or industrial packaging.

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Action: Confirm whether packaging falls within scope, obtain appropriate supplier declarations and test evidence,and retain the technical documentation needed to demonstrate compliance.

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‍‍What to Do Next

•    Assess products that may contain PFAS and identify CAS numbers of concern.

•    Determine volume and sales territories for products affected by PFAS regulations.

•    Build a program for collecting, analyzing, tracking, and monitoring PFAS in your products.

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Turn PFAS uncertainty into an action plan. Ask for our PFAS assessment report and get a review of your product documentation, compliance gaps, and practical next steps. Contact us today to discuss next steps.

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Get your BlueCircle PFAS Assessment Quote Today

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Links

Packaging and Packaging Waste Regulation (EU) 2025/40

European Commission, “Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste” (C/2026/3084)

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Neeta

Neeta Verma is a senior environmental compliance and enterprise quality governance leader with over 27 years of experience in the global electronics industry. Her expertise spans environmental compliance,regulatory strategy, product stewardship, and quality governance,connecting regulatory intelligence with business strategy to help organizations anticipate change, reduce risk, and build sustainable, resilient compliance practices across global operations. She has held progressive leadership roles with Accuris,S&P Global, IHS Markit, and PartMiner.

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