PFAS in food-contact packaging: the three limits in force from 12 August 2026
From 12 August 2026, packaging intended for contact with food products cannot be placed on the market if it contains PFAS at a concentration equal to or above three limit values.
- Legal reference
- Art. 5(5)
- Last updated
- Official text
- Regulation (EU) 2025/40
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There are three limit values. Point (c) is the only one that includes polymeric PFAS, and it is omitted from most of the summaries in circulation.
The three limit values
Article 5(5) of Regulation (EU) 2025/40:
| Limit value | Method | Polymeric PFAS | |
|---|---|---|---|
| (a) | 25 ppb | targeted PFAS analysis | excluded from quantification |
| (b) | 250 ppb | sum of targeted analysis, where relevant after prior degradation of precursors | excluded from quantification |
| (c) | 50 ppm | total PFAS | included |
The ban is triggered at values equal to or above the threshold, not only above it. A value exactly equal to the limit is already non-compliant.
The provision applies without prejudice to any case where the placing on the market of such packaging is already prohibited by another Union legal act.
The trigger based on total fluorine
Attached to point (c) is an obligation that is not a concentration limit, but a burden of proof placed on the supply chain:
"if total fluorine exceeds 50 mg/kg, the manufacturer, importer or downstream user […] shall provide, on request, to the manufacturer or importer […] evidence of the amount of fluorine measured as PFAS or non-PFAS content so that they can draw up the technical documentation referred to in Annex VII."
The practical meaning is precise: once that total-fluorine threshold is exceeded, the undertaking is entitled to demand analytical proof from its own supplier, and the supplier is required to provide it. It is not a commercial courtesy.
It is the second foothold of this kind, after Article 16, which generally places on suppliers of packaging or materials the obligation to transmit the information necessary to demonstrate conformity.
(Note: the internal cross-reference in this point was corrected by Corrigendum 2025/90971 of 28 November 2025, which replaces "Article 3, points 1, 13 and 17" with "Article 3(1), points 13 and 17". The limit values themselves were not changed.)
What is meant by PFAS
The definition is set out in the text, and it is broader than the everyday one:
"any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom (without any H/Cl/Br/I attached to it)"
excluding substances that contain only certain structural elements specified in the rule.
Who it applies to
Only to packaging intended for contact with food products. Shipping packaging that does not come into contact with the food does not fall under this provision, but remains subject to the heavy metals limit under paragraph 4. That limit knows only two exemptions, those under Decisions 2001/171/EC and 2009/292/EC for glass and for plastic crates and pallets, which Article 70(3) keeps in force.
Take care not to read "food" as "the food sector". The criterion is the intended use of the packaging, not the undertaking’s business classification.
How conformity is demonstrated
Paragraph 6 of Article 5 is clear:
"Compliance with the requirements set out in paragraphs 4 and 5 shall be demonstrated in the technical documentation drawn up in accordance with Annex VII."
It is not enough, therefore, for the values to be within the threshold: this must appear from the technical documentation, with the tests and reports on which the assessment is based (Annex VII, point 2(f)).
The limit that applies to all packaging
Not to be confused with the above. Paragraph 4 of the same article provides that the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium resulting from substances present in the packaging or in its components does not exceed 100 mg/kg.
This limit applies to all packaging, not only food packaging, and provides for no size-based exemptions.
The dates to keep in mind
- 12 August 2026 · the PFAS ban applies
- 31 December 2026 · the Commission, assisted by the European Chemicals Agency, prepares a report on the presence of substances of concern in packaging
- 12 August 2030 · the Commission assesses whether to amend or repeal paragraph 5, to avoid overlaps with the PFAS restrictions established by other Union acts
References
Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, in OJ L of 22 January 2025. Applicable from 12 August 2026.
- Art. 5(4) · heavy metals limit, 100 mg/kg
- Art. 5(5) · PFAS limit values in food-contact packaging
- Art. 5(6) · conformity is demonstrated in the technical documentation
- Art. 16 · information obligations of suppliers of packaging or packaging materials
- Annex VII, point 2 · content of the technical documentation
- Corrigendum 2025/90971 of 28 November 2025
Official text: http://data.europa.eu/eli/reg/2025/40/oj