Since 12 August 2026, food-contact packaging with PFAS above set limits can no longer be placed on the EU market. In the US, the market for PFAS grease-proofing agents has effectively closed, and many states have their own bans. For burger wraps, fries bags and pizza box liners, where the grease barrier was for years often a fluorinated treatment, moving to PFAS-free food packaging is therefore a specification task: choose a barrier that works with your menu, prove it with the right test, and hold documents that will satisfy authorities and chain auditors.
This guide covers the EU and US rules that drive the change, the barrier options that replace fluorochemistry, the difference between the test methods, and the paperwork to request from a packaging manufacturer. It is not legal advice; confirm your obligations with the relevant authority, your compliance scheme or counsel.
Status as of October 2026; check the official source: Regulation (EU) 2025/40 on EUR-Lex (Article 5), the US FDA's pages on PFAS in food contact applications, and each state's environmental or health agency.
What are the EU PFAS limits for food packaging under the PPWR?
From 12 August 2026, Article 5(5) of the Packaging and Packaging Waste Regulation (EU) 2025/40 prohibits placing food-contact packaging on the EU market if it contains PFAS above three thresholds: 25 ppb for any single PFAS measured by targeted analysis, 250 ppb for the sum of PFAS measured by targeted analysis, and 50 ppm for all PFAS including polymeric PFAS. There is no sell-off period for stock made earlier but placed on the market after that date; according to the Commission's guidance, packaging already placed on the market before it may stay on the market.
| Measure | Limit | What it captures | Typical method |
|---|---|---|---|
| Any single PFAS | 25 ppb (µg/kg) | Individual non-polymeric PFAS on the analytical list | Targeted analysis, usually LC-MS/MS |
| Sum of PFAS | 250 ppb (µg/kg) | Total of the PFAS measured by targeted analysis | Targeted analysis |
| PFAS incl. polymeric PFAS | 50 ppm (mg/kg) | All PFAS, including polymeric PFAS; total fluorine above 50 mg/kg triggers a proof-of-source duty | Total fluorine, usually combustion ion chromatography, as the first screening step |
The 50 ppm limit covers PFAS including polymeric PFAS. Where total fluorine exceeds 50 mg/kg, the supplier of the material must, on request, provide the packaging manufacturer or importer with proof of how much of the fluorine is PFAS or non-PFAS, for the technical documentation. The Commission's June 2026 guidance recommends total fluorine as the first enforcement test: below 50 mg/kg, a sample can be considered compliant. Packaging types most affected are greaseproof and glassine papers, burger and pizza boxes, fries and bakery bags and moulded fibre, where fluorinated grease-proofing was historically common.
The restriction applies across all Member States without national transposition, because the PPWR is a regulation. It sits alongside the general food-contact framework in Regulation (EC) 1935/2004, covered in our food-contact packaging compliance guide.
What is the US position on PFAS in food packaging?
The US has no single federal PFAS limit in packaging, but the FDA announced on 28 February 2024 that PFAS grease-proofing substances are no longer being sold for food-contact use in the US, and in January 2025 it determined that 35 PFAS Food Contact Notifications were no longer effective, with existing stock usable until 30 June 2025. In parallel, many states ban intentionally added PFAS in food packaging.
| State | Effective date (food packaging PFAS restriction) | Note |
|---|---|---|
| New York | 31 Dec 2022 | |
| California (AB 1200) | 1 Jan 2023 | |
| Washington | 1 Feb 2023 / 1 May 2024 | Phased by product category (wraps, plates, food boats, pizza boxes first; bags, bowls, flat serviceware, open-top and closed containers from May 2024) |
| Vermont | 1 Jul 2023 | |
| Connecticut | 31 Dec 2023 | |
| Colorado | 1 Jan 2024 | |
| Maryland | 1 Jan 2024 | |
| Minnesota | 1 Jan 2024 | |
| Hawaii | 31 Dec 2024 | |
| Rhode Island | 1 Jan 2025 | Originally 1 Jan 2024; postponed by 2023 and 2024 amendments to R.I. Gen. Laws ch. 23-18.13. PFAS used as a processing aid count as intentionally added from 1 Jul 2027 if detected |
| Oregon | 1 Jan 2025 | Foodware containers |
| Maine | 25 May 2026 | Nine plant-fibre food packaging types under Maine DEP rule (Chapter 80, Section 5); exemption for food and beverage manufacturers with under USD 1 billion annual national sales |
The practical baseline across these laws is no intentionally added PFAS. Several states use total organic fluorine thresholds, commonly 100 ppm, as an indicator, and BPI compostability certification applies a limit of 100 ppm total organic fluorine. Because state definitions, scope and enforcement differ, check each state where you distribute. Our US foodservice packaging regulations guide puts PFAS alongside EPR and bag laws.
The PPWR is an EU regulation and does not apply in Great Britain, and as of October 2026 GB has no specific restriction on PFAS in food contact materials. The UK PFAS Plan (Defra, February 2026) commits to testing and monitoring PFAS in food contact materials, with the extent tied to the UK-EU SPS agreement, which is still being negotiated and would cover food contact materials. Northern Ireland follows EU food-contact rules under the Windsor Framework, and DAERA states that the PPWR's product requirements apply there to packaging placed on the market from 12 August 2026 (its reuse, EPR and deposit return provisions do not), so the PFAS limits should be treated as applying in NI. Many UK chains specify fluorine-free papers anyway so that one specification serves UK and EU outlets; confirm the current GB position with the Food Standards Agency.
Who is responsible for PFAS compliance?
The packaging manufacturer is responsible for producing compliant packaging and holding test evidence; in the EU, the party placing the packaging on the market and every later operator must not supply non-compliant packaging. In practice, brand owners and chains set the requirement, importers verify it before placing goods on the market, and distributors pass documents on.
Brand owner or chain
Under the PPWR, a brand owner that has packaging designed or manufactured under its own name or trademark can itself be the "manufacturer" for conformity purposes. If your logo is printed on the wrap, expect your auditors and authorities to look to you as well as to the converter. Specify "no intentionally added PFAS" and the PPWR limits in your packaging specification, and require test data per material.
Importer
An importer placing packaging from outside the EU on the market must check that the manufacturer has carried out conformity assessment, that the EU Declaration of Conformity and technical documentation exist, and add its own name and address. For PFAS, that means holding or being able to obtain test reports covering the imported material. A US importer needs equivalent evidence for each state's law.
Distributor
A distributor must not make packaging available if it knows or should know that it does not comply, and must keep supplier documentation. Mixed stock (old fluorinated wraps alongside new fluorine-free ones) is a typical risk after a cut-off date with no sell-off period.
Foreign manufacturer
A converter outside the EU or US must source fluorine-free papers and boards, confirm that coatings, inks, adhesives and process chemicals add no PFAS, test representative samples, and hold technical documentation. It relies on mill declarations for base papers, so upstream traceability is as important as finished-product testing.
What replaces PFAS as a grease barrier?
There is no single drop-in replacement; the right choice depends on grease load, temperature, holding time, fold or crease stress and the recyclability you need. The main options are mechanically densified (greaseproof) pulp, water-based dispersion coatings, extruded PE or biopolymer layers, wax, and smarter structural design.
| Option | How it resists grease | Strengths | Limitations | Typical applications |
|---|---|---|---|---|
| Dense greaseproof pulp | Heavy refining closes the fibre network so oil cannot wick through | No added coating; prints well; good for wraps | Grease resistance falls at creases and with long hot holds; cost tied to refining | Burger wraps, sandwich sheets, bakery papers, basket liners |
| Water-based dispersion coating | Thin polymer film applied from water | Repulpable in many mills; heat-sealable variants | Performance varies by formulation and coat weight; check fold cracking | Fries bags, food bags, cups, boxes |
| PE extrusion coating | Continuous plastic layer | Very high grease and moisture barrier | Classed as plastic layer; recyclability and SUP status to consider | Cups, containers, high-moisture boxes |
| Biopolymer (e.g. PLA) coating | Continuous bio-based layer | Barrier similar to PE in many uses | Industrial composting rarely available; still a plastic for SUP purposes | Cups, containers |
| Wax or wax blends | Hydrophobic surface layer | Moisture resistance, low cost | Limited heat resistance; may affect recycling | Deli and sandwich paper |
| Structural design | Venting, liners, trays, reduced contact area | Reduces barrier demand | Needs design work | Pizza and burger boxes, multi-item orders |
A grease barrier that passes a lab test may still fail in service at the fold of a burger box or the base of a fries bag. Test with your real food at real holding times. The comparison of coating chemistries and their recyclability is covered in depth in our guide to barrier coatings for paper packaging, and the standard grease rating method in KIT test and grease resistance ratings explained.
How is PFAS in packaging tested?
Use both kinds of test: targeted analysis tells you which listed PFAS are present and in what amount; total fluorine or total organic fluorine (TOF) screens for everything containing fluorine, including polymeric PFAS that targeted methods miss. The EU limits require both views.
- Targeted analysis (typically LC-MS/MS) measures a defined list of individual PFAS. It is precise at low ppb levels but only sees compounds on the list. Ask which analytes and which reporting limits the lab used; a "not detected" result is only meaningful if the reporting limit is below 25 ppb.
- Total fluorine (typically combustion ion chromatography) measures all fluorine in the sample, organic and inorganic. It is the usual first screen for the EU limit of 50 ppm for all PFAS including polymeric PFAS; it is not itself the limit, but a result above that level obliges the supplier to prove how much of the fluorine comes from PFAS.
- Total organic fluorine (TOF) excludes inorganic fluoride and is used as an indicator of intentionally added PFAS in several US states, commonly at 100 ppm. BPI compostability certification applies a limit of 100 ppm total organic fluorine.
Inorganic fluorine can come from minerals or fillers in paper, so a total fluorine result above a screening level is a prompt for investigation, not proof of PFAS. Test the finished, printed article or at least the base paper plus coating, because inks and coatings can contribute. Repeat testing whenever the paper grade, mill, coating or ink system changes.
Timeline for PFAS in food packaging
| Date | Jurisdiction | Event |
|---|---|---|
| 31 Dec 2022 | New York | First state food packaging PFAS ban in this list takes effect |
| 1 Jan 2023 | California | AB 1200 applies |
| 28 Feb 2024 | US federal | FDA announces PFAS grease-proofing agents no longer sold for food contact |
| Jan 2025 | US federal | FDA determines 35 PFAS FCNs no longer effective |
| 11 Feb 2025 | EU | PPWR (EU) 2025/40 enters into force |
| 30 Jun 2025 | US federal | End of use of existing stock under the withdrawn FCNs |
| 25 May 2026 | Maine | PFAS prohibition for nine plant-fibre food packaging types takes effect |
| 12 Aug 2026 | EU | PPWR PFAS limits apply to food-contact packaging; no sell-off period |
Documents to request from your packaging manufacturer
- Written statement that no PFAS are intentionally added at any stage (paper, coating, inks, varnishes, adhesives, process aids).
- Targeted PFAS analysis report for each material, with the analyte list and reporting limits.
- Total fluorine report (and TOF where US states or BPI apply), with method and laboratory named.
- Mill declarations for base papers and boards, and coating supplier declarations.
- EU Declaration of Conformity and summary of technical documentation under the PPWR for EU supply.
- Food-contact Declaration of Compliance covering the same material and conditions of use (see food-contact packaging compliance).
- Change-control commitment: notification before any change of paper, coating or ink supplier.
At 9 Packaging, the barrier, test plan and document set for each item are confirmed during quotation and technical review, since they depend on the food, format and destination market.
What this means for foodservice and e-commerce packaging
- Greaseproof wraps and liners: switch to fluorine-free dense greaseproof grades or coated papers; verify fold performance. See custom printed greaseproof paper.
- Food bags for fries, pastries and kebab: dispersion-coated or greaseproof papers; check heat-seal and base grease marking. See custom printed paper food bags.
- Burger and pizza boxes: board itself rarely needs fluorine treatment if venting, liners or barrier coatings are specified correctly. See custom printed burger boxes and custom printed pizza boxes.
- Takeaway boxes for saucy food: dispersion or PE barrier on the food side. See custom printed takeaway food boxes.
- E-commerce mailers: outside food contact the PPWR PFAS restriction does not apply, but chains selling food online often request the same PFAS-free standard for inner food packaging.
Next step: write the PFAS requirement into your specification
Add three lines to every food packaging specification: "no intentionally added PFAS", "complies with Regulation (EU) 2025/40 Article 5(5) limits" (for EU supply) and "complies with PFAS laws in [list of US states]" (for US supply), plus the test reports you expect per material. Then describe the food, temperature and holding time so the supplier can propose the right barrier. Send that specification with your request for quotation or directly via our contact page.