Three alternative limit values, one date, and a documentation duty. This page sets out what Article 5(5) of Regulation (EU) 2025/40 says, what it leaves open, and what to ask your suppliers for.
Check your food-contact packaging
Summary
From 12 August 2026, food-contact packaging must not be placed on the market in the Union if it contains per- and polyfluorinated alkyl substances (PFAS) at or above any of three limit values set in Article 5(5) of Regulation (EU) 2025/40. The prohibition applies to the extent that placing on the market of packaging with such a concentration is not already prohibited by another Union legal act.
The three values are alternatives, not a combined test. Packaging that reaches or exceeds any one of them is caught: 25 ppb for any single PFAS measured by targeted analysis, 250 ppb for the sum of PFAS measured by targeted analysis, or 50 ppm for PFAS in total including polymeric PFAS. The first two exclude polymeric PFAS from quantification; the third includes them.
Compliance is not shown by a label or a supplier's assurance alone. Article 5(6) requires it to be demonstrated in the technical documentation drawn up under Annex VII, and the tests, measurements and calculations behind it must use reliable, accurate and reproducible methods with low uncertainty (Article 35).
Responsibility sits with several parties. The manufacturer may place on the market only packaging that conforms to Articles 5 to 12 and must prepare the documentation and the EU declaration of conformity. The importer must check that the manufacturer has done so. The distributor must act with due care. Suppliers must give the manufacturer the information it needs.
This page covers Article 5(5) only. The separate limit of 100 mg/kg on the sum of lead, cadmium, mercury and hexavalent chromium is in Article 5(4). PFAS in packaging that does not touch food are not limited by this paragraph, although other Union law may apply to them. The Commission must evaluate by 12 August 2030 whether paragraph 5 should be amended or repealed to avoid overlap with other PFAS restrictions.
The three PFAS limit values
Packaging is caught if it contains PFAS at or above any one of these values. The values are written in the Regulation as ppb and ppm; 1 ppm equals 1,000 ppb, so the limits differ by orders of magnitude and are not interchangeable.
| Point | Limit | What is measured | Treatment of polymeric PFAS | Note |
|---|---|---|---|---|
| (a) | 25 ppb | Any single PFAS, by targeted PFAS analysis. | Excluded from quantification. | Applies to each individual PFAS found, not to the total. |
| (b) | 250 ppb | The sum of PFAS, as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors. | Excluded from quantification. | Precursor degradation is part of the measurement where it applies. |
| (c) | 50 ppm | PFAS in total, including polymeric PFAS. | Included. | If total fluorine exceeds 50 mg/kg, proof of the quantity of fluorine measured as PFAS or non-PFAS content must be supplied on request. |
Article 5(5) does not state the reference basis for ppb and ppm or name an analytical standard. Ask the testing laboratory to state the basis and method in every report, and keep that statement in the technical documentation.
What counts as a PFAS
Article 5(5) defines PFAS as any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, meaning one without any hydrogen, chlorine, bromine or iodine atom attached to it. The definition excludes substances that contain only certain listed structural elements, namely CF3-X or X-CF2-X', where X is an -OR or -NRR' group and X' is a methyl, methylene, aromatic or carbonyl group or an -OR'', -SR'' or -NR''R''' group. Because the definition is structural, a product is not outside the rule merely because it is not sold as a fluorochemical. The precise wording is in the Official Journal text and should be used by the laboratory and in your documentation.
Who has to do what
| Role | What the Regulation requires | Article |
|---|---|---|
| Packaging manufacturer | Place on the market only packaging that conforms to Articles 5 to 12. Carry out the conformity assessment, draw up the technical documentation and the EU declaration of conformity, keep them for 5 years (single-use) or 10 years (reusable), and keep series production in conformity when the design or materials change. | 15 |
| Supplier of packaging or packaging materials | Give the manufacturer all information and documentation needed to demonstrate conformity, including what is required for the Annex VII documentation. | 16 |
| Chemical manufacturer, importer or downstream user (REACH roles) | Where total fluorine exceeds 50 mg/kg, provide on request the packaging manufacturer or importer with proof of the quantity of fluorine measured as PFAS or non-PFAS content, so that the technical documentation can be completed. | 5(5)(c) |
| Importer | Before placing packaging on the market, check that the manufacturer carried out the conformity assessment and drew up the technical documentation, that the required documents accompany the packaging and that the manufacturer's identification is present. Do not place non-conforming packaging on the market. Keep a copy of the EU declaration of conformity for 5 or 10 years. | 18 |
| Distributor | Act with due care. Where there is reason to believe packaging does not conform, do not make it available until it has been brought into conformity, and inform the market surveillance authorities. | 19 |
| Importer or distributor under its own brand | Treated as the manufacturer, with the manufacturer's duties, when packaging is placed on the market under its own name or trademark or modified in a way that could affect conformity. | 21 |
How compliance is shown
Article 5(6) states that compliance with paragraphs 4 and 5 is demonstrated in the technical documentation drawn up under Annex VII. Annex VII sets out Module A, internal production control, under which the manufacturer establishes the documentation and declares on its sole responsibility that the packaging satisfies Articles 5 to 12.
For PFAS, the parts of the documentation that matter most are the general description and intended use of the packaging, the materials of its components, the list of standards and other technical specifications used for measurement, an explanation of the solutions adopted where no standard is applied, and the test reports. The documentation must also include an analysis and assessment of the risks of non-conformity.
The manufacturer then draws up a written EU declaration of conformity for each packaging type, using the model in Annex VIII, which includes the unique identification of the packaging, the manufacturer's name and address, and references to the standards or specifications used. The declaration is kept together with the technical documentation for 5 years for single-use packaging and 10 years for reusable packaging after placing on the market.
Article 35 requires that the tests, measurements and calculations used to verify compliance use reliable, accurate and reproducible methods that take into account generally recognised state-of-the-art methods and whose results have low uncertainty. In practice this means test reports should identify the laboratory, the method, the sample and the measurement uncertainty.
What to ask suppliers for
This checklist is a practical suggestion built on the documentation duties above. It is not wording taken from the Regulation.
- A list of every component of each food-contact packaging unit, with its material, so you can tell what has to be tested.
- A written statement from each supplier on whether PFAS are present in the material or in coatings, barrier layers, inks or adhesives used on it.
- Test reports from targeted PFAS analysis showing results against the 25 ppb single-substance limit and the 250 ppb sum limit, with the method, laboratory, sample and measurement uncertainty stated.
- Where total fluorine may exceed 50 mg/kg, the proof of how much fluorine is PFAS and how much is not, which the chemical supplier must provide on request.
- A commitment to notify you before any change of formulation, coating or source material, so that you can re-assess before series production continues.
- A retention rule: keep the reports with the technical documentation and the EU declaration of conformity for 5 or 10 years.
What the text leaves open
We read Article 5(5), Article 35 and Annex VII in the Official Journal text. The following points are not settled by those provisions, and we do not offer a view on them.
- Packaging already placed on the market before 12 August 2026. The Regulation defines placing on the market as the first making available of packaging on the Union market. The provisions read for this page do not separately address stock, so ask your national authority before relying on any assumption.
- Which analytical standard to use. Article 5(5) refers to targeted PFAS analysis but names no standard, and Article 35 sets only general quality criteria for methods.
- The reference basis of the ppb and ppm values, which the paragraph does not state.
- How paragraph 5 interacts with other Union restrictions on PFAS and with the rules on food-contact materials. The text applies it only to the extent that another Union legal act does not already prohibit placing on the market, and provides for the Commission's evaluation by 12 August 2030.
Exemptions
Article 5(5) lists no exemptions by sector, material or enterprise size in its own text. The Regulation as a whole applies without prejudice to Union requirements on the safety, quality, health and hygiene of packed products, and where it conflicts with Directive 2008/68/EC on the transport of dangerous goods, that Directive prevails (Article 2(2)). A related provision, Article 5(8), allows the Commission to adopt delegated acts on exemptions for the heavy-metals limit in Article 5(4), not for the PFAS limits.
PPWR Readiness Check
Check your food-contact packaging
Frequently asked questions
Which PFAS limits apply to food-contact packaging?
From 12 August 2026: 25 ppb for any single PFAS, 250 ppb for the sum of PFAS, or 50 ppm total PFAS including polymeric PFAS (Art 5(5)).
Does the PPWR PFAS limit apply to packaging that does not touch food?
Article 5(5) sets these limits for food-contact packaging only. Other Union acts, such as REACH or the rules on food-contact materials, may apply separately.
What proof is needed for the PFAS limits?
Compliance with Article 5(5) must be shown in the Annex VII technical documentation. If total fluorine exceeds 50 mg/kg, the chemical manufacturer, importer or downstream user must on request give the packaging manufacturer or importer proof of the quantity of fluorine measured as PFAS or non-PFAS content.
Sources
Facts last checked against the Official Journal text on 6 November 2026.
This page is general information, not legal advice. Obligations depend on your role, packaging and Member State. Check the official text on EUR-Lex.