The PFAS Limits: What Applies from 12 August

On 30 March 2026, the European Commission published its Guidance document and FAQ on the implementation of the Packaging and Packaging Waste Regulation (PPWR). For food contact packaging manufacturers, this is a meaningful step forward: the Commission has clarified the testing methodology for PFAS compliance, confirmed that there is no transitional period for existing stock, and identified the one major open question still being resolved. Not everything has been settled at once — and it is worth knowing precisely what has been addressed and what has not.

From 12 August 2026, food contact packaging may not be placed on the EU market if it contains PFAS above defined thresholds. The new Guidance sets out a stepwise testing approach, removes any doubt about the absence of stock exhaustion arrangements, and names a June 2026 deadline for resolving the multi-component packaging question.

The PFAS Limits: What Applies from 12 August

Regulation (EU) 2025/40 sets three PFAS thresholds for food contact packaging:

• 25 ppb for any single non-polymeric PFAS substance (targeted analysis)
• 250 ppb for the sum of non-polymeric PFAS (targeted analysis)
• 50 ppm where polymeric PFAS are present

When total fluorine content exceeds 50 mg/kg, supply chain actors must be able to demonstrate on request whether that fluorine originates from PFAS or other sources.

The Guidance confirms that packaging manufactured before 12 August 2026 that does not meet PFAS limits cannot be placed on the market after that date. There is no grandfathering provision. For companies that assumed existing stock would be covered by some form of exemption: it will not be.

What the Commission Has Clarified: A Stepwise Testing Methodology

The most practically useful element of the new Guidance is a three-step approach to verifying PFAS compliance. No harmonised analytical standard exists yet, but the Commission recommends robust analytical methodologies and sets out a clear sequence:

• Step 1: Measure total fluorine (TF). If TF is below 50 ppm, the packaging is compliant and no further testing is required.
• Step 2: If TF exceeds 50 ppm, methods such as pyrolysis GC/MS are recommended to confirm whether the fluorine is organic or inorganic. If organic fluorine is below 50 ppm, the packaging can be considered compliant.
• Step 3: If compliance remains unresolved after Step 2, direct total oxidizable precursors (TOP) analysis is used to check against the 25 ppb and 250 ppb concentration limits.

This is practical guidance that manufacturers can act on now. In many cases, full targeted PFAS analysis will not be necessary: if Step 1 or Step 2 confirms compliance, testing can stop there. For companies planning their testing programmes and budgets, this matters.

What Remains Open: Multi-Component Packaging

This is where manufacturers of complex packaging still face uncertainty. The question is whether PFAS limits apply to each individual packaging component separately or to the complete assembled packaging unit as a whole.

It is not a theoretical question. Products currently on the market include:

• Beverage cans with pull tabs, protective linings, and closures
• Glass bottles with composite closures (metal caps, plastic seals, sometimes cork with surface treatments)
• Ready-meal trays with multiple barrier layers
• Multi-material coffee capsules
• Blister packs with backing cards

In many of these products, PFAS may be present only in one small component — a gasket, a barrier coating, a surface treatment — representing a tiny fraction of total packaging mass. Whether that component is tested in isolation or as part of the assembled unit can produce entirely different compliance outcomes.

The Commission has established a dedicated task force on PFAS testing methodology in food contact packaging, operating under the PPWR Expert Group, with conclusions expected by June 2026 — ahead of the August application date. The involvement of DG SANTE, DG ENV, and the EU Reference Laboratory for Food Contact Materials suggests the conclusions will reflect both food safety considerations and industrial realities.

No Transitional Period: What This Means for Supply Chain Planning

The Guidance does indicate that empty packaging that does not meet PFAS limits may be legally sold before 12 August 2026 and used to fill products thereafter. This is a nuance that matters for supply chain planning — but it only applies to transactions that close before the deadline, not after.

For importers and companies managing cross-border supply chains, this requires immediate attention. Stock management decisions made now will determine whether August 2026 is a manageable transition or an operational problem.

What to Do Now: Concrete Steps

The publication of the Guidance is not a signal to pause. It is a signal to accelerate.

• Apply the stepwise testing methodology to your key products. Start with total fluorine measurement. In many cases this will be sufficient to confirm compliance without the cost and time of full targeted PFAS analysis.
• Map your multi-component packaging and actively monitor the task force conclusions expected in June 2026. This is the one open question with a defined resolution timeline.
• Review your existing stock: which packaging that does not yet meet limits can be placed on the market before 12 August? The Guidance permits this for empty packaging sold before the deadline — but not after.
• Request PFAS declarations from component suppliers. Some are still not fully aware of the scope and consequences of these requirements.
• Prepare your Declaration of Conformity (DoC). This is a mandatory requirement from 12 August 2026 and belongs to the manufacturer as defined under PPWR, not the packaging supplier.
• Track the broader REACH PFAS restriction process: the Committee for Risk Assessment (RAC) adopted its final opinion on 2 March 2026. The Socio-Economic Analysis Committee (SEAC) is expected to finalise its opinion by end of 2026. This is the wider regulatory trajectory shaping the next several years.

The Broader Picture: This Is the Beginning, Not the End

PPWR PFAS limits are one element of a much wider regulatory picture. The universal PFAS restriction under REACH is at an advanced procedural stage. France introduced a national PFAS water pollution levy that entered into force on 1 March 2026. Other Member States are expanding national measures. The direction of travel is clear.

For food contact materials manufacturers, PPWR is the immediate compliance challenge, but it sits within a broader and accelerating shift toward stricter scrutiny of chemical substances in materials contacting food. Building robust chemical management systems now — knowing what is in your materials, mapping your supply chain, developing processes to assess and substitute substances of concern — will serve you well beyond August 2026.

In Summary

The Commission’s 30 March 2026 Guidance is a genuine step forward. The testing methodology is now clear. The absence of a transitional period is confirmed. The multi-component packaging question has a defined resolution timeline of June 2026.

Manufacturers who implement the stepwise testing approach now, map their multi-component portfolios, prepare their compliance documentation, and review their stock positions will be significantly better placed than those still waiting for every piece of guidance before they begin.

August 2026 is closer than it looks. Acting on the clarity that exists is better than waiting for clarity that has not yet come.

Working with food contact packaging manufacturers on PFAS compliance and PPWR implementation. If you have questions about regulatory interpretation or compliance strategy, feel free to reach out.

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