PFAS evidence under the PPWR: regulatory compliance made simple
A complex supply chain? Test and communicate what actually reaches the market.
PFAS are among the substance groups currently under the closest scrutiny from regulators, science and the public. For the packaging industry this has become a very concrete requirement:
Since 12 August 2026, PFAS limit values under Article 5(5) of the European Packaging and Packaging Waste Regulation (PPWR) apply directly to food contact packaging for the first time.
Regulation (EU) 2025/40 sets three relevant thresholds:
25 ppb for a single PFAS determined by target analysis,
250 ppb for the sum of PFAS determined by target analysis,
50 ppm for PFAS including polymeric PFAS.
That leaves manufacturers, brands and importers with a very practical question:
How can you demonstrate reliably that the finished packaging meets these requirements, particularly when many international suppliers, materials and intermediate stages are involved?
The PPWR does not prescribe an unbroken chain of individual PFAS-free declarations from every upstream supplier as the method of proof. What matters is that compliance with the PFAS limit values can be demonstrated in the technical documentation under Annex VII, as required by Article 5(6).
From a supply chain dossier to a measurable end product
Coatings, barriers, printing inks, adhesives, additives, recycled materials and changing raw material suppliers can turn a single pack into a complex overall system.
The PPWR contains numerous information duties along the supply chain. For the PFAS evidence itself, however, documented conformity of the packaging is enough.
What is measured is the packaging in exactly the composition in which it is later placed on the market.
Independent testing and certification of the finished packaging can therefore supply the direct evidence of compliance with the PFAS limit values and be taken into the technical documentation under Article 5(6) and Annex VII PPWR. The PFAS evidence does not have to rest on a multitude of individual supplier declarations and the near endless bureaucracy that comes with them.
The European Commission's current PPWR guidance explicitly supports this approach: under Article 15(2) the manufacturer may carry out the conformity assessment procedure itself or have it carried out. The Commission expressly names a laboratory or a certification scheme as possible external bodies.
Independent external certification to flustix PFAS-FREE is therefore not an add-on detached from the PPWR, but a route expressly provided for within PPWR conformity assessment.
Regulatory evidence: PFAS proof on the end product
“What the independent assessment examines is the packaging as it will actually be placed on the market.”
Depending on packaging material, matrix and risk profile, it covers among other things:
a product and matrix specific evaluation,
target PFAS analysis,
additional fluorine and sum parameters,
testing by laboratories accredited to ISO/IEC 17025,
conformity assessment and issuing of the certificate.
One process: prove it to the regulator, communicate it with confidence
With flustix PFAS-FREE, a single testing and certification process produces two things you can use straight away:
1. Regulatory evidence
Independent analytical proof of the PFAS limit values on the finished product, for the technical documentation under Article 5(6) and Annex VII PPWR, without having to maintain individual supplier declarations at great bureaucratic cost.
2. PFAS-FREE certification
Beyond the regulatory evidence, certification lets you communicate the assessed product property visibly to customers, retailers and consumers.
flustix PFAS-FREE certification rests on an independent certification scheme with defined, publicly available requirements and external conformity assessment. It therefore meets what the Empowering Consumers for the Green Transition Directive (EmpCo, applying from 27 September) asks of credible voluntary sustainability labels and their independent substantiation.
PFAS: from a compliance topic to a consumer topic
How quickly invisible chemicals reach public awareness can be seen with microplastics.
A study published in 2026 with the involvement of EFSA and BfR shows that 76.6 % of respondents already know what microplastics are; concern about possible environmental effects stands at 4.49 out of 5, and about possible health effects at 4.13 out of 5.
PFAS and microplastics are scientifically different subjects. In communication terms the challenge is the same:
What consumers can neither see nor judge for themselves needs credible confirmation that can be checked independently.
This is exactly where flustix brings the two together:
Test the finished product.
Create the PPWR evidence.
Certify independently.
Communicate in line with EmpCo.
PFAS compliance. Made simple.
With flustix PFAS-FREE, complex PFAS substantiation becomes a structured process, from the analytical proof on the end product through to independently secured communication.
The flustix network consists exclusively of internationally accredited testing and certification partners.
More information:
→ https://flustix.com/en/pfas-free/
More background on consumer perception and credible communication:
→ Whitepaper: new EFSA/BfR study, consumers expect guidance on microplastics
Have your packaging assessed for PFAS-FREE:
→ Get in touch / request certification