Does the PFAS requirement apply to all packaging?

The Article 5 requirement applies to food packaging, meaning packaging in contact with food. Other packaging is covered by other requirements.

Is there a transition period?

According to the Commission's guidance there is no transition period for packaging placed on the market after 12 August 2026. Packaging placed on the market before that date may remain on the market.

Do we have to test every package?

Not necessarily. Evidence can consist of a material declaration and a supplier statement, with test reports where needed. Prioritise by risk and document your assessment.

Food packaging PFAS: PPWR supplier evidence

What applies since 12 August 2026?

Food packaging placed on the EU market from 12 August 2026 must not contain PFAS above the PPWR limits. One of the values is 25 ppb for individual PFAS by targeted analysis. There are also limits for the sum of PFAS and for total PFAS content. According to the Commission's guidance, published on 5 June 2026, there is no transition period for packaging placed on the market after the date. Packaging already placed on the market before 12 August may remain on the market.

The PFAS requirement is part of the conformity assessment behind your DoC.

Start with the right priorities

Not all packaging carries the same risk. Go through your items in this order:

1. Is it food-contact packaging? If not, other requirements apply and the food-packaging PFAS limit is not relevant.
2. Which materials and coatings are used? Grease-resistant coatings and some printed or treated surfaces are examples that usually need checking.
3. Which supplier is behind it, and what evidence do you have today?

What evidence should you ask suppliers for?

The exact evidence depends on the packaging and your role, but these are common starting points:

Material declaration and specification per item.
Supplier statement on the PFAS status of the material concerned.
Test reports from an accredited laboratory when needed, stating the analytical method.
Change procedure: how the supplier tells you when materials or formulations change.

Ask for evidence in one consistent format, linked to item numbers and supplier item numbers. Otherwise you cannot link the right document to the right packaging when the DoC is issued.

Document it so it holds up

Store the evidence in the technical documentation per item.
Record date and version for every document.
Flag gaps immediately. Do not issue a DoC before the evidence is complete.
Decide who owns updates when the supplier changes something.

How CO2check helps

In CO2check's PPWR portal, suppliers upload their evidence per item, gaps are flagged, and an outgoing DoC is not generated if incoming documentation is missing. That makes PFAS evidence part of the same flow as the rest of your documentation instead of a separate email track. Read more about the PPWR solution or download the PPWR checklist 2026.

General information, not legal advice. Check limits and exemptions in the regulation text and the Commission's guidance.

PFAS in food packaging: what the PPWR requires and what evidence suppliers should provide