This is not just a supplier issue. It directly affects:
- Manufacturers of packaged goods
- Brand owners
- Importers placing products on the EU market
Even packaging already produced and “on the roll” will be affected if it is first placed on the market after 12 August 2026.
In this article, we explain what PFAS are, which packaging formats are at risk, who is responsible, how companies should approach PFAS risk assessment, and how digital packaging management tools like Packa support PFAS compliance.
Table of Contents
- What Are PFAS?
- Why PFAS in Packaging Is a Growing Compliance Risk
- The 2026 EU PFAS Ban Under PPWR
- Who Is Responsible for PFAS Compliance?
- Which Packaging Materials Have PFAS Risk?
- PFAS in Food vs. Non-Food Packaging
- No Official Testing Method – What Companies Should Do
- The Risk-Based Methodology
- What Data Is Required for a PFAS Risk Assessment?
- Step-by-Step: How to Prepare for PFAS Compliance
- Why Packaging Data Management Is Critical
- How Packa Supports PFAS Compliance
1. What Are PFAS?
PFAS (per- and polyfluoroalkyl substances) are a large group of synthetic chemicals used for their water-, grease-, and oil-repellent properties. They are often referred to as “forever chemicals” because they are highly persistent in the environment and the human body.
In packaging, PFAS are commonly used in:
- Grease-resistant paper and cardboard
- Coatings and surface treatments
- Laminates and barrier layers
- Adhesives and processing aids
Due to their environmental persistence and potential health risks, PFAS are increasingly restricted worldwide.
2. Why PFAS in Packaging Is a Growing Compliance Risk
PFAS regulation is tightening globally. Existing restrictions already include:
- EU POPs Regulation (PFOS, PFOA, PFHxS)
- REACH Annex XVII restrictions
- EU Food Contaminants Regulation
The PPWR PFAS ban from 12 August 2026 significantly increases regulatory pressure specifically on food contact packaging.
For companies placing packaged goods on the EU market, PFAS is no longer just a chemical topic. It is a:
- Market access requirement
- Compliance risk
- Brand reputation issue
- Supply chain transparency challenge
3. The 2026 EU PFAS Ban Under PPWR
From 12 August 2026, food contact packaging containing PFAS above defined thresholds will be prohibited.
Important:
All food contact packaging first placed on the EU market after 12 August 2026 must comply, even if:
- It was produced before that date
- It is already in storage
- It is currently in stock
This makes inventory planning and packaging specification control critical.
4. Who Is Responsible for PFAS Compliance?
PFAS compliance is not limited to packaging suppliers.
Responsible parties include:
- Manufacturers of packaged goods
- Brand owners
- Importers placing products on the EU market
If you place a packaged product on the EU market after 12 August 2026, you are responsible for ensuring that the packaging complies.
This shifts the focus from supplier declarations alone to structured packaging compliance management.
5. Which Packaging Materials Have PFAS Risk?
PFAS risk is not limited to one material group.
Paper and Cardboard
- Grease barriers
- Oil-resistant coatings
- Fast-food packaging
- Bakery and takeaway packaging
Plastic Packaging
- Barrier coatings
- Surface treatments
- Adhesives and laminating glues
- Processing aids
Both paper-based packaging and plastic packaging can contain PFAS depending on formulation and functional requirements.
6. PFAS in Food vs. Non-Food Packaging
The PPWR ban primarily targets food contact packaging.
However, even for non-food packaging, companies must consider the Minimierungsgebot (minimization principle) under chemicals regulation and general product safety obligations.
This means:
- PFAS risks should be assessed across all packaging types
- Substitution strategies may become necessary
- Transparency requirements will likely expand
7. No Official Testing Method - What Companies Should Do
Currently, there is:
- No delegated act defining a harmonized testing methodology
- No single mandatory analytical standard
This creates uncertainty.
Testing every packaging type without prioritization is inefficient and costly.
A structured, risk-based approach is necessary.
8. The Risk-Based Methodology
Step 1: Identify High-Risk Packaging
Determine which packaging formats have a functional risk for PFAS, for example:
- Grease barriers
- Oil-repellent properties
- Special surface treatments
- Multi-layer laminates
Step 2: Conduct Targeted Testing
Only after identifying risk-relevant packaging should laboratory testing be performed.
This avoids:
- Unnecessary testing costs
- Inefficient blanket analysis
- Supply chain confusion
This risk-based screening model is currently considered best practice in the absence of official methodology guidance.
9. What Data Is Required for a PFAS Risk Assessment?
A proper PFAS risk assessment requires more than a simple material name.
Companies need:
1. Full Material Structure
- Substrate (paper, PET, PE, PP, etc.)
- Layer structure
- Barrier layers
2. Coatings and Surface Treatments
- Functional coatings
- Grease barriers
- Chemical treatments
3. Adhesives and Laminating Glues
- Laminating adhesives
- Tie layers
4. Extended Material List (“Erweiterte Materialliste”)
Only by combining:
- Material structure
- Coatings
- Laminating adhesives
can a proper PFAS risk evaluation be performed.
Without structured packaging specifications, this information is often fragmented across emails, PDFs, and supplier declarations.
10. Step-by-Step: How to Prepare for PFAS Compliance
- Map all food contact packaging SKUs
- Build an extended material list for each packaging specification
- Identify PFAS risk categories
- Engage suppliers with structured questionnaires
- Conduct targeted laboratory testing
- Document results and compliance status
- Monitor regulatory updates
The earlier companies start, the lower the risk of supply disruption in 2026.
11. Why Packaging Data Management Is Critical
PFAS compliance is fundamentally a packaging data problem.
Companies must manage:
- Hundreds or thousands of packaging specifications
- Multiple suppliers
- Regional variations
- Changing formulations
Without a centralized packaging management system:
- Risk identification becomes manual
- Data is inconsistent
- Compliance documentation is incomplete
- Audit readiness is weak
Digital packaging data management is no longer optional.
12. How Packa Supports PFAS Compliance
Packa is a specialized packaging management software designed to centralize packaging specifications, workflows, and compliance data.
For PFAS compliance, Packa helps companies:
1. Build Structured Packaging Specifications
- Store full material structures
- Document coatings and laminating adhesives
- Maintain extended material lists
2. Identify PFAS Risk Across Portfolios
- Filter packaging by functional properties (e.g., grease resistance)
- Categorize risk-relevant packaging formats
- Create compliance dashboards
3. Standardize Supplier Data Collection
- Structured questionnaires
- Version-controlled documentation
- Transparent communication
4. Document Compliance Status
- Store test results
- Link laboratory reports
- Track regulatory thresholds
5. Ensure Audit Readiness
- Centralized documentation
- Clear responsibility tracking
- Traceable change history
With increasing regulatory pressure under PPWR and PFAS restrictions, companies need more than spreadsheets. They need a digital system that connects packaging data, compliance requirements, and supplier communication.
Packa enables structured PFAS risk assessment, targeted testing strategies, and full documentation, all in one centralized packaging management platform.
Conclusion: PFAS Compliance Requires Action Now
The PFAS ban in food contact packaging from 12 August 2026 is approaching quickly.
Companies that:
- Lack structured packaging data
- Do not understand their material composition
- Rely only on supplier statements
face significant compliance risks.
A risk-based methodology combined with centralized packaging data management is the most efficient path forward.
PFAS compliance is not just a chemical issue, it is a strategic packaging management challenge.
And companies that digitalize their packaging specifications today will be significantly better prepared for 2026 and beyond.
Talk to us now to understand how Packa can help you with PFAS Compliance
Disclaimer: This content is for informational purposes only and does not constitute legal advice.