PFAS in food contact packaging: three limits and one misunderstanding

Since 12 August 2026 three PFAS limits apply to food contact packaging. A total fluorine analysis can be a sensible screening step. On its own, however, it is not enough as proof of conformity.

The limits are set out in Article 5 of the EU packaging regulation. They apply to packaging intended to come into contact with food and refer to different analytical levels.

The three limits

• 25 ppb for individual PFAS in targeted analysis
• 250 ppb for the sum of the PFAS analysed in the target list
• 50 ppm for PFAS including polymeric PFAS

If one of these limits is reached or exceeded, the food contact packaging concerned may in principle not be placed on the market, unless stricter prohibitions under Union law already apply.

There is also an obligation that is often overlooked: where the total fluorine content is above 50 mg/kg, the manufacturer or importer must show on request which share of the measured fluorine is attributable to PFAS and which to other sources of fluorine.

Why total fluorine alone is not enough

The total analysis measures fluorine, not individual PFAS. A low figure can give an unremarkable screening result, but it does not automatically replace the assessment against the lower limits for individual or summed target substances. Conversely, an elevated fluorine value can have other causes and therefore needs further clarification.

Solid evidence therefore combines a document review of the materials used with suitable targeted analysis, a sum parameter as screening and a technical conformity assessment.

The targeted analysis has to match the material

Which substances are examined determines how much the result says. Besides classic long chain PFAS, short chain compounds and substitutes can also be relevant depending on material, application and method. A historical standard panel therefore does not answer today’s regulatory question in every case.

Conformity and claim are two separate checks

The PPWR governs whether a food contact pack may be placed on the market. Where PFAS freedom or a sustainability label is also used in advertising, the new consumer protection requirements for environmental claims and certification schemes have applied since 27 September 2026 as well.

Anyone who wants not only to comply with PFAS freedom but also to communicate it to customers or consumers therefore needs a suitable test of the product and a solid framework for the claim.

How flustix PFAS-FREE is structured, which limits apply per product group and which label variants are available is explained on our PFAS-FREE page.