If a supplier sends you a PFAS test report for food-contact packaging, read the first test on it before anything else. Under Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation (PPWR), applicable from 12 August 2026 — the cheapest and fastest check is total fluorine, and a result below 50 mg/kg settles the question without any PFAS-specific analysis at all. Buyers who ask for a PFAS screen first usually pay several times more for an answer they could have had from a combustion test.
What Article 5 restricts, and from when
Article 5 of the PPWR sets three separate ceilings for food-contact packaging. They are not three ways of measuring the same thing, and a report can pass one while failing another.
- 25 ppb — any individual PFAS, by targeted analysis.
- 250 ppb — the sum of PFAS found by targeted analysis, including after degradation of precursors.
- 50 mg/kg (50 ppm) — total PFAS content, which is the only one of the three that includes polymeric PFAS.
The restriction has no transitional period for packaging placed on the EU market on or after 12 August 2026. Packaging placed on the market before that date may continue to be sold and used, so the question for a buyer is not whether a pack is legal today but whether the next production run is.
The three-step route the Commission recommends
The European Commission's guidance of 10 June 2026 (Commission Notice C/2026/3084) notes that no harmonised EU-wide method exists for PFAS in food packaging, and recommends a progressive route instead of going straight to targeted analysis.
Step 1 — total fluorine (TF). Typically combustion ion chromatography. A result below 50 mg/kg is treated as compliant.
Step 2 — only if Step 1 is at or above 50 mg/kg. Pyrolysis GC-MS to separate organic fluorine, which is where PFAS sit, from inorganic fluorine, which is not.
Step 3 — only if organic fluorine is confirmed. Targeted PFAS analysis plus a total oxidisable precursors (TOP) assay, against the 25 ppb and 250 ppb ceilings.
The Commission adds a point that matters commercially: on current knowledge, samples that pass Step 1 also pass Steps 2 and 3. A low total-fluorine result is therefore not a partial answer — it is the answer.
Which test answers which question
| What you need to know | Test that answers it | Why the others do not |
|---|---|---|
| Is this pack in scope at all? | Total fluorine (combustion ion chromatography) | Targeted analysis only finds the substances on its list; a low TF result covers the whole fluorine family |
| Is the fluorine organic or inorganic? | Pyrolysis GC-MS | TF cannot distinguish them — mineral fillers, kaolin, talc and calcium carbonate all contribute fluorine readings |
| Which PFAS, and how much? | Targeted analysis plus TOP assay | Neither TF nor pyrolysis gives a substance-level figure against the 25 ppb and 250 ppb ceilings |
| Will it migrate into food? | Migration testing under the intended conditions | Content limits and migration limits are different obligations — passing one does not demonstrate the other |
Where buyers misread the report
- Treating a positive total-fluorine result as a PFAS finding. Inorganic fluorine reads as fluorine. A mineral-coated board can return a TF figure above the screening level with no PFAS present at all, which is exactly why Step 2 exists.
- Testing the finished pack only. The coating, the ink, the adhesive and the liner are separate components, and Article 5 applies to the packaging and its components. A clean substrate with a fluorinated adhesive is still non-compliant.
- Asking for "a PFAS certificate". There is no single certificate. What exists is a test report stating a method, a limit of quantification and a result — ask for those three, not for a document title.
- Assuming a declaration is enough. A supplier declaration is a starting point for the compliance file, not a substitute for a result where a limit applies.
FAQ
Does a low total-fluorine result need to be confirmed by targeted analysis?
Not under the Commission's recommended route. Step 1 below 50 mg/kg is treated as passing, and the Commission states that samples passing Step 1 also pass Steps 2 and 3.
Is recycled fibre a problem for the heavy-metal and PFAS limits?
It can be. Recycled fibre is one of the routes by which both legacy substances and fluorine enter a pack, so a recycled-content grade needs its own evidence rather than inheriting the virgin grade's.
What does the report need to state to be usable?
The method, the limit of quantification, the result, the component tested, and the date. A figure without a method and a detection limit cannot be compared against a regulatory threshold.
Where does the limit apply — the pack or the material?
To the packaging and its components. That is why the component list matters as much as the number on the report.
Browse the range
For the regulatory background in full, see our PFAS-free packaging market and technology white paper. The water-based barrier coating paper range is built on an aqueous coating system with no fluorochemical greaseproof agent, and the wider materials library lists the grades by base paper and barrier level. Tell us the destination market, the food type and the pack construction, and we will confirm the grade and the documentation you need. Compliance documentation is provided offline on request; we do not publish certificate numbers online.
More in this series: recyclability grades A, B and C · the 100 mg/kg heavy-metal sum · EPR and the authorised representative