PFAS Ban Takes Effect in Packaging
Barely two months remain of the preparation period the European Union gave the packaging industry. From 12 August 2026 – under Article 5 of the Packaging and Packaging Waste Regulation (PPWR, officially Regulation (EU) 2025/40) – it is prohibited to place on the EU market food contact packaging containing per- and polyfluoroalkyl substances (PFAS) at concentrations at or above the limits set in the regulation. The ban introduces one of the strictest PFAS restrictions on food contact packaging in the world, and there is no way around it: guidance published by the European Commission on 30 March 2026 made clear that there is no grace period for selling off stock, meaning food packaging with PFAS above the limits cannot be placed on the EU market after 12 August.
What exactly do the limits require?
The PPWR introduces three parallel thresholds for PFAS content.
From 12 August, food contact packaging may not contain more than 25 ppb of any individual non-polymeric PFAS, more than 250 ppb of the sum of all targeted non-polymeric PFAS, or more than 50 ppm of total PFAS – including polymeric PFAS.
The Commission recommends tiered testing, starting with total fluorine (TF) – if the value stays below 50 ppm, the packaging can be considered compliant. If total fluorine exceeds 50 ppm, the second step uses methods such as pyrolysis-GC/MS to separate organic and inorganic fluorine, and – if necessary – targeted PFAS analysis to check compliance with the 25 ppb and 250 ppb limits.
The burden of proof lies with the manufacturer and supplier. If testing shows organic fluorine above 50 ppm, the burden of proof is reversed: the manufacturer or supplier must show that the fluorine detected does not come from a prohibited PFAS.
Crucially, the rule does not apply only to products made after 12 August. The PPWR provides no transition period for selling off existing stock: packaging placed on the market before 12 August may remain on the market and be used, but packaging placed on the market after that date must meet the limits – regardless of when it was produced.
The limits apply to all food packaging placed on the EU market after 12 August, even if it was produced before that date.
This poses a serious inventory risk: what counts is not production but placing on the market – that is, the date of filling, or of release for free circulation for imported products.
Who is directly affected by the ban?
The PFAS ban is not a narrow technical issue; it sweeps through the entire food supply chain. PFAS have traditionally been used in applications such as fast-food wrapping paper, pizza boxes, microwave popcorn bags and takeaway food containers, because their water- and grease-repellent and heat-resistant properties made them ideal for these purposes. The rule therefore primarily affects packaging manufacturers, which must switch to PFAS-free coatings by 12 August; secondly, food and bakery businesses; and thirdly, food service and retail chains selling takeaway food in paper or cardboard packaging.
Bio-based PFAS-alternative coatings cost between $0.015 and $0.98 per square metre, compared with just $0.00012 per square metre for conventional PFAS treatment – a price gap that shows the economic burden the switch places on the packaging industry.
The risk is increased further by the fact that, given the size of portfolios, not every type of packaging can be tested in time: testing typically takes four to eight weeks per sample, requiring risk-based prioritisation for manufacturers with large product portfolios.
The water dimension
The packaging PFAS ban is not an isolated step but part of a much broader EU chemicals strategy. The limits set in the PPWR are consistent with the European Chemicals Agency's (ECHA) universal PFAS restriction proposal, but take effect much sooner than ECHA's proposed restriction is expected to. This parallel signals that packaging is only the first stop in a longer regulatory process that may extend to other sectors in future – including water treatment and drinking water safety.
The sources and pathways of PFAS pollution are closely intertwined: PFAS from packaging, textiles or industrial use enter the same environmental cycle as pollution from other sources – groundwater, surface water and ultimately drinking water sources. Under the EU Drinking Water Directive, member states must continuously test PFAS levels in drinking water, so reducing emissions from packaging could also ease the burden on water utilities in the longer term.
The packaging PFAS ban is thus not an isolated measure but one link in a broader EU PFAS strategy affecting several sectors – including water.
What alternatives are emerging?
The packaging industry is being forced to change materials, and the change is already under way. For years the industry has been looking for an alternative that provides grease, oil and moisture resistance while remaining flexible enough for paper-based packaging, thin enough not to affect machine processing, and stable enough to withstand heat and humidity throughout the supply chain. During late 2024 and 2025, this iteration produced results usable at commercial scale in two main technological directions – water-based coatings and bio-based solutions.
The industry is not moving towards a single dominant solution but towards system-level material choices: fibre-based packaging combined with functional coatings, bio-based packaging with grease-resistant properties, compostable food contact systems, and hybrid structures combining fibre and functional layers are all in the running.
One concrete example shows the industry's momentum: Impermea Materials and INX International have formed a strategic partnership to commercialise OLEO PAK 4100, a PFAS-free, polyethylene-free barrier coating that gives paper and fibre packaging the same grease and moisture resistance previously provided by plastic films.
Sanctions and lack of preparation
The consequences of non-compliance are not negligible. Packaging exceeding the PFAS limits faces mandatory market withdrawal. National authorities can also impose fines for PPWR violations, whose amount varies by jurisdiction and severity, but can reach levels that significantly affect a company's financial performance.
The problem is that many companies still underestimate the need to prepare. The absence of a grandfathering clause (an exemption for existing stock) makes preparation even more urgent than usual: organisations cannot rely on sell-off periods or phased roll-out timetables. Compliance is also not a one-off project: issuing a Declaration of Conformity and the five-year documentation retention obligation require robust systems that manual processes can no longer sustain at scale.
Legal uncertainty also makes preparation harder, since the testing methodology is not yet harmonised.
The European Commission has issued guidance and an FAQ document on the PPWR, but these – although highly authoritative – are not binding, and the Commission has not prescribed a final testing methodology or conformity procedure, leaving companies uncertain about how compliance with the limits can be demonstrated in practice.
Summary
The PPWR's PFAS rule becomes mandatory in barely two months, from 12 August 2026, without a transition period. The 25 ppb, 250 ppb and 50 ppm thresholds force the packaging industry, the food industry and food service alike to replace conventional PFAS-based grease- and water-resistant coatings with water-based or bio-based alternatives as soon as possible. The ban also applies to products already made but placed on the market after the deadline – a serious inventory risk for unprepared companies – while the testing methodology is not yet fully harmonised. Non-compliance can bring fines, market bans, recalls and reputational damage. Although the rule is primarily about packaging, together with ECHA's parallel universal PFAS restriction proposal it is part of a broader EU strategy affecting several sectors – including water.
From 12 August 2026 it is prohibited to place on the EU market food contact packaging that reaches or exceeds the PFAS thresholds set in the PPWR. The limits are 25 ppb for any individual non-polymeric PFAS, 250 ppb for their sum and 50 ppm for total PFAS content. The rule takes effect without a transition period and also applies to packaging already produced but placed on the market after 12 August. The measure mainly affects greaseproof papers, pizza boxes, paper cups and bakery packaging – and so the packaging industry, the food industry and food service alike. Manufacturers are switching to water-based and bio-based alternatives, although these cost considerably more than conventional PFAS treatment. Non-compliance can bring fines, market bans, recalls and reputational risk. Together with ECHA's parallel universal PFAS restriction proposal, the rule is part of a wider EU strategy that will also affect the water sector in the longer term.
From 12 August 2026, under Article 5 of the Packaging and Packaging Waste Regulation (PPWR), it is prohibited to place on the European Union market food contact packaging that reaches or exceeds the PFAS concentration limits set in the regulation. The three parallel thresholds are 25 ppb for any individual non-polymeric PFAS, 250 ppb for the sum of non-polymeric PFAS and 50 ppm for total PFAS content, including polymeric PFAS. The European Commission's March 2026 guidance recommends a tiered testing methodology but does not prescribe a mandatory test procedure, which creates legal uncertainty. The rule takes effect without a transition period and applies not only to packaging made after 12 August but also to packaging produced earlier and placed on the market after the deadline – a significant inventory risk for unprepared companies.
The measure mainly affects greaseproof papers, pizza boxes, paper cups, bakery packaging and microwavable containers, hitting packaging manufacturers, the food industry and food service at once. Manufacturers are switching to water-based and bio-based alternatives, whose cost per square metre can be up to a thousand times that of conventional PFAS treatment. The consequences of non-compliance can be severe: fines, mandatory market withdrawal, recalls and reputational damage. Many companies still underestimate the need to prepare, even though, without a grandfathering clause, old stock cannot be carried over past 12 August. Although the rule is primarily about packaging, it is consistent with ECHA's parallel universal PFAS restriction proposal and is part of a broader EU strategy affecting several sectors – including water and drinking water safety.
A study of 10,826 Chinese treatment plants finds that big centralised systems are reaching two limits at once, on easing water scarcity and on paying their way, and that a hybrid model could do the job for up to 37% less.
FAO has published draft principles on who may use water and on what terms, a quiet piece of international work that speaks directly to this year's fights over drought, wells and free irrigation.
A new report projects data centres' water footprint reaching 9.32 trillion litres by 2030, but the number is only meaningful once you know what it counts, and who is making the case.
An English coalition has costed what it would take to keep every drop of wastewater out of England's largest lake, £3.6–3.7 billion, and its modelling says nothing less ends harmful algal blooms.
