PFAS in food contact packaging – compliance strategy ahead of the August 2026 deadline

Client: leading global packaging manufacturer | 

The situation

From 12 August 2026, the new Packaging and Packaging Waste Regulation (PPWR) prohibits placing food contact packaging on the market if PFAS concentrations exceed defined thresholds. For manufacturers of multi-component packaging, such as cans with lids, ready-meal trays or multilayer packs, the regulation raises a fundamental question: must PFAS limits be met by each packaging component separately, or by the assembled unit as a whole? The European Commission’s answer: guidance is being developed. The client needed to act now.

Our role

We advised the client on managing the regulatory uncertainty arising from the absence of Commission guidance, so that operational activities and business decisions are not put on hold waiting for clarification that may arrive too late. We developed a testing and documentation strategy for compliance under both possible interpretations. We monitored the PPWR task force work and engage in consultation processes on behalf of the client.

The result

The client is acting, not waiting passively. It has a clear compliance strategy regardless of which interpretation the Commission ultimately confirms. The case is a good example of pre-standard advisory work: we help clients make well-founded business decisions when regulations have already been adopted but their application remains unclear.

Do PPWR and PFAS limits in packaging affect your production? Get in touch — the August 2026 deadline is closer than it seems.