Is a total fluorine analysis sufficient as PFAS evidence?

Under the current PPWR guidance, a total fluorine analysis can be sufficient as a first testing step. The European Commission recommends a stepwise testing approach as long as no harmonised EU test method for PFAS in food-contact packaging is available.

If total fluorine content is below 50 mg/kg, or 50 ppm, the sample can be regarded as compliant within this approach recommended by the Commission. According to the data currently available to the Commission, samples that passed this first step also passed the subsequent steps.

If total fluorine content is above 50 mg/kg, further investigation is required, in particular to distinguish between organic and inorganic fluorine and, where relevant, to assess the other PFAS limits.

The guidance is an aid to interpretation, and no harmonised EU test method exists to date. The testing approach behind flustix PFAS-FREE deliberately goes beyond this regulatory minimum and is correspondingly more robust as evidence.