PFAS — per- and polyfluoroalkyl substances — are a family of ~10,000 synthetic chemicals prized in food packaging for their grease and water resistance (pizza boxes, microwave popcorn bags, fast-food wrappers). They are also persistent, bioaccumulative, and increasingly linked to adverse health outcomes. PPWR Article 5 closes the regulatory gap by setting a direct, low-threshold limit on PFAS in food-contact packaging.
The rule, in one sentence
What “food-contact packaging” covers
The Article 5 PFAS restriction applies to any packaging layer that is — or may become — in direct contact with food during normal or foreseeable use. This includes:
Inner layers of multilayer pouches (chocolate, snack, freeze-dried).
Greaseproof papers used for bakery, butter, and fast-food wrap.
Inner films and bag linings in cereal, pet food and grain packaging.
Closures and seals on jars and bottles that touch the product head-space.
Outer layers and secondary packaging (transport boxes, pallets, shipping cartons) are out of scope unless the food is exposed to them in normal use — for example, bulk pet-food sacks that double as the consumer pack.
What 25 ppb means in practice
25 ppb is a very low bar — roughly the level historically used to distinguish “intentionally added” PFAS from background contamination from food, water, or recycled fibre. In practice, the threshold means:
Intentionally fluorinated packaging is out. Any product that uses fluorochemistry for grease resistance (Zonyl, Capstone, fluoroether oligomers) will exceed 25 ppb by 2–3 orders of magnitude.
Recycled fibre needs verification. Recycled cardboard can pick up trace PFAS from cosmetic, hygiene, or technical-paper streams. Recycled-content food packaging needs supplier certification of the recyclate feedstock.
PTFE-coated processing equipment. Some bakery and confectionery lines use PTFE belts; trace migration can push otherwise PFAS-free packaging over threshold. Cleaning and changeover protocols matter.
Are there exemptions?
Article 5(2)–(4) anticipates two narrow exemption channels:
Exemption
Conditions
Status as of 2026
Polymeric PFAS in fluoropolymer barrier films
Used in regulated medical-device-equivalent applications where no alternative exists; subject to a Commission delegated act.
Pending — no qualifying application has been granted for general food packaging.
Trace background contamination
PFAS below the limit of quantification (LoQ) of the test method, demonstrated by accredited lab.
Treated as “not detected”; not a substantive exemption.
How to test and document
Article 5(7) directs the Commission to specify test methods via implementing acts. In practice, the methods of record are:
EN 17681-1 / -2 — extractable organic fluorine (EOF) as a screening method, followed by targeted LC-MS/MS analysis for the 40+ regulated PFAS species.
ISO/TS 23926 — total organic fluorine combustion ion chromatography (CIC), used as a faster screening tool.
National method equivalents — Danish AFFF method, German BfR guidance — accepted where they produce results comparable to EN 17681 within stated tolerance.
A passing test result is documented in the Declaration of Conformity (see Article 11) as a cited line item: “PFAS < LoQ (25 µg/kg) per EN 17681-1, test report XYZ dated YYYY-MM-DD, accredited laboratory ABC.” Authorities will request the underlying test report on inspection.
The Commission's March 2026 guidance frames PFAS testing as a three-step decision tree:
Step
Test
Outcome
1
Total fluorine (TF) screening
< 50 ppm → compliant, stop here
2
Targeted PFAS analysis (LC-MS/MS)
Each non-polymeric PFAS < 25 ppb AND the sum < 250 ppb → compliant
3
Fluorine source identification
TF > 50 ppm: provide evidence of how much fluorine is PFAS vs non-PFAS
What to ask suppliers right now
For every food-contact SKU in your portfolio, you need three pieces of evidence from the upstream material supplier:
A written confirmation of no intentionally added PFAS in the packaging material or its production aids.
A test report meeting EN 17681 (or equivalent) showing total PFAS < 25 µg/kg.
For recycled-content packaging: a chain-of-custody declaration on the recyclate feedstock excluding PFAS-contaminated streams.
→ Carbonorm tracks PFAS status (none / exempt / non-exempt) per SKU, sends magic-link data requests to suppliers for missing test reports, and refuses to generate a Declaration of Conformity for any food-contact item without a clean PFAS result.
Penalties for non-compliance
Article 5 violations are calibrated nationally under Article 67, but member-state guidance points to the upper end of the penalty schedule because PFAS is treated as a substance-of-concern violation rather than a design defect:
Germany — up to €5 000 per SKU placed on the market, with a market-withdrawal order.
France — administrative fine up to €15 000 per item under DGCCRF authority.
Italy — penalty up to €25 000 plus seizure of the affected lots.