The new Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, is changing the way packaging compliance should be approached in the European Union. The PPWR replaces the previous Directive 94/62/EC and will apply from August 12, 2026, introducing a directly applicable and more harmonized framework across Member States.
The Regulation is not only focused on waste management. It reflects a broader regulatory shift towards packaging prevention, recyclability, recycled content, minimization and control of substances of concern. In this context, one key issue for operators is the presence of PFAS in food-contact packaging.
Why are PFAS relevant for packaging compliance?
PFAS, often referred to as “forever chemicals”, are a broad group of substances used across several industrial sectors because of their resistance to water, grease, heat and chemicals. Their use is not limited to packaging and may involve, among others, textiles, cosmetics, industrial applications and manufacturing processes.
In the EU, PFAS are also subject to a broader regulatory discussion under REACH. In March 2023, national authorities submitted a request to ECHA for a restriction of PFAS as a group, moving away from a substance-by-substance approach.
For companies, this means that PFAS compliance should not be treated only as a finished-product issue. The assessment may need to cover raw materials, coatings, additives, processing aids, recycled inputs, supplier documentation and possible contamination along the supply chain.
Will food-contact packaging containing PFAS be banned from 2026?
The PPWR introduces a specific restriction for food-contact packaging.
From 12 August 2026, food-contact packaging shall not be placed on the EU market when containing PFAS at or above specific concentration limits: 25 ppb for any PFAS measured by targeted PFAS analysis, 250 ppb for the sum of targeted PFAS, and 50 ppm for PFAS including polymeric PFAS.
This does not mean that all packaging will be banned in 2026. It means that food-contact packaging will need to be assessed against clear thresholds, and compliance will have to be demonstrated through appropriate technical documentation.f
From a practical perspective, the key question is not only whether PFAS have been intentionally added. Operators should also consider whether PFAS may be present due to coatings, surface treatments, inks, adhesives, recycled materials or other inputs used in the production process.
How do REACH and the PPWR overlap?
The REACH PFAS restriction proposal and the PPWR requirement are linked, but they are not the same instrument.
REACH addresses PFAS from a chemical regulation perspective, potentially affecting substances, mixtures and articles across many sectors. The PPWR already introduces a specific requirement for PFAS in food-contact packaging.
This creates an important overlap for companies placing packaging on the EU market. A material may need to be assessed both as an article potentially affected by chemical restrictions under REACH and as packaging intended to come into contact with food under the PPWR and Regulation (EC) No 1935/2004.
This distinction is particularly relevant because a material that appears acceptable from a general chemical compliance perspective may still require a dedicated food-contact assessment. Conversely, a food-contact evaluation that does not consider REACH may underestimate future restrictions affecting substances or manufacturing processes.
What comes after the 2026 PFAS deadline?
Why is an integrated assessment needed?
PFAS in packaging is a multidisciplinary issue at the intersection of chemical regulation and food safety.
At Chemsafe, the Chemical and Food Business Units work together to assess packaging materials from both perspectives. This allows companies to verify not only whether a material is compliant under REACH, but also whether it can be considered safe and compliant as a food-contact material under the PPWR and Regulation (EC) No 1935/2004.
This integrated approach is particularly important in the current transition phase. Companies should not wait for the 2026 deadline to review their packaging portfolio. A structured assessment can help identify critical materials, request meaningful supplier documentation, define analytical strategies and anticipate the additional requirements that will become relevant from 2030.
Packaging compliance is becoming a technical and regulatory strategy that starts from material selection and supply chain control.
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