For a long time, PFAS substances were primarily discussed in connection with industrial emissions, firefighting foams, or contaminated sites. However, a recent case in Scotland clearly shows that these chemicals represent a far more difficult-to-define problem than previously thought. Fair Isle, one of the most remote inhabited islands in the United Kingdom, came into focus after drinking water tests revealed exceptionally high PFAS levels for Scotland, despite the absence of any obvious industrial source that could explain the contamination. According to researchers, PFAS substances may have reached this isolated location through sea spray and sea foam, meaning via environmental systems themselves.
This story is important because it highlights one of the greatest challenges of PFAS pollution: these substances do not necessarily remain where they are used. They can appear in water, soil, living organisms, food, packaging materials, and even in places that seem far removed from industrial emissions.
For companies, this is particularly significant because PFAS is no longer just an environmental or health issue, but increasingly a matter of compliance, supply chain management, and market access risk. The EU’s new Packaging and Packaging Waste Regulation (PPWR) introduces, from 12 August 2026, specific limits on the PFAS content of food-contact packaging. This means that PFAS compliance becomes a very tangible task for businesses: they must know what packaging they use, what substances those materials contain, and whether they have the documentation proving compliance.
What are PFAS compounds?
PFAS is the collective name for per- and polyfluoroalkyl substances. According to the widely used OECD definition, these are fluorinated substances that contain at least one fully fluorinated methyl or methylene carbon atom to which no hydrogen, chlorine, bromine, or iodine atom is attached. In simpler terms, these are fluorinated chemicals with a particularly stable chemical structure that makes them extremely slow to break down in the environment.
It is important to clarify terminology: the Hungarian legal text of the PPWR refers to these substances as “PFA substances.” However, in international literature, English-language EU documents, and business practice, the abbreviation PFAS is widely used. For clarity and consistency with international usage, this article uses the term PFAS, while also noting the Hungarian legal designation in sections discussing the PPWR.
Thousands of compounds belong to this chemical group, which have been used for decades in a wide range of industrial and consumer products. One of the main attractions of PFAS substances is their valuable technological properties: they enable water-, grease-, oil-, and dirt-repellent surfaces. As a result, they are found in products such as firefighting foams, textiles, non-stick coatings, industrial applications, and certain types of food-contact packaging.
The problem stems from this same chemical stability. Some PFAS compounds degrade extremely slowly in the environment, which is why they are often called “forever chemicals.” Some PFAS are mobile and can spread through water, while others can accumulate in living organisms. Their environmental presence therefore appears not as a one-off pollution event, but as a long-term burden.
According to data from the European Environment Agency, PFAS contamination is widely detectable in European waters. A 2024 analysis by the agency examining the presence of PFOS — one of the best-known members of the PFAS group — found that in many European water bodies, measured concentrations exceed environmental quality standards. This is an important signal: PFAS is not an isolated, exotic environmental issue, but a pollution risk that is also present in European water systems.
Why can they pose health risks?
Health research on PFAS substances has examined a range of potential effects. These include impacts on the immune system, hormonal system, reproductive system, and development, as well as possible associations with certain types of cancer. It is important to emphasize that not all PFAS compounds have the same level of available data, and the risks associated with individual substances may differ. At the same time, the regulatory direction is clear: authorities are increasingly moving toward prevention and reducing exposure.
The European Food Safety Authority (EFSA) has established a group tolerable weekly intake for four PFAS compounds — PFOA, PFNA, PFHxS, and PFOS — at 4.4 nanograms per kilogram of body weight per week.
This is important for companies because the PFAS issue is not a communication exaggeration or a passing regulatory trend. It concerns a group of substances where scientific evidence, regulatory risk assessments, and policy measures are increasingly pointing in the same direction: environmental and human exposure must be reduced.
What does this have to do with packaging?
Many people primarily associate PFAS substances with firefighting foams, industrial emissions, or contaminated drinking water. However, the world of packaging is also affected, particularly in the case of food-contact materials.
PFAS-related risks typically arise where packaging is required to provide grease-, oil-, water-, moisture-resistant, or non-stick properties. This can include certain grease-resistant papers, coated cardboard, fast-food and takeaway packaging, bakery and ready-meal packaging, pizza boxes, molded fiber-based packaging, and other materials that come into direct contact with food.
This is particularly important in thinking about sustainable packaging
In recent years, many companies have focused primarily on whether packaging is recyclable, contains recycled content, can be reduced in weight, or can be replaced from plastic to paper. These are indeed important questions, but they are not sufficient on their own. A package is not sustainable simply because it is paper-based or recyclable if it contains chemical substances that may hinder safe circularity or pose environmental and health risks.
PPWR: PFAS becomes a concrete compliance issue from August 2026
In a previous article, Sustainable Development already highlighted that the EU’s new Packaging and Packaging Waste Regulation (PPWR) is one of the most important European sustainability regulations of recent years. The regulation is directly applicable, and from 12 August 2026 several key obligations will enter into force.
This article focuses on a specific but particularly urgent area for companies: the restriction of PFAS in food-contact packaging.
Based on Article 5 of the PPWR, from 12 August 2026 it will no longer be possible to place on the market food-contact packaging that contains PFA substances — or, in international terminology, PFAS substances — at or above the concentration limits defined in the regulation. The regulation sets three threshold values:
- 25 ppb for any individual PFA substance, measured via targeted analysis of PFA substances (polymeric PFA substances are not included in the value);
- 250 ppb for the sum of PFA substances, measured via targeted analysis of the total PFA substances, including, where applicable, pre-degradation of precursors (polymeric PFA substances are not included in the value); and
- 50 ppm for PFA substances (including polymeric PFA substances); where total fluorine content exceeds 50 mg/kg.
This regulatory shift is significant because PFAS content is no longer merely a product development or sustainability question, but a market access requirement. If food-contact packaging contains PFAS substances at or above the specified limits, such packaging cannot be placed on the EU market after 12 August 2026.
However, it is important to be precise. The PPWR does not mean that every company must automatically test every piece of packaging in a laboratory. The essence of the obligation is that companies must be able to demonstrate compliance. In practice, this may involve supplier declarations, material composition information, food contact documentation, technical documentation, change management processes, and risk-based laboratory testing.
The emphasis, therefore, is not on testing itself, but on verifiable compliance.
Which companies may be affected?
The PFAS restriction does not affect only packaging manufacturers or food retail chains. According to the logic of the PPWR, a company’s exposure is not determined by whether it considers itself part of the packaging industry, but by its role in the packaging life cycle and in the EU market.
For example, it may affect food manufacturers, beverage producers, quick-service restaurant or HORECA operators, retailers, private-label product companies, importers, packaging manufacturers, e-commerce players, logistics companies, and any economic operator that places packaged products on the market under its own name, imports packaged goods, or uses food-contact packaging.
Roles under the PPWR can differ by product and packaging level
Under the PPWR, a company’s role may vary depending on the product and the packaging stage. A company can act as a manufacturer or producer, importer, distributor, or final distributor. In the case of private-label products, packaging placed on the market under one’s own name or trademark, packaged goods imported from outside the EU, or modifications affecting packaging compliance, different levels of responsibility may apply.
This is important because companies cannot simply claim that “the supplier handles the packaging.” While the supply chain is of course a key stakeholder, PPWR compliance requires companies to understand their own role and to have the necessary documentation in place.
What needs to be done in practice?
PFAS compliance does not start in the laboratory, but in the packaging database and in supply chain transparency. The first task is to understand what types of packaging the company uses, places on the market, imports, or sells.
As a first step, it is advisable to map all food-contact packaging. This may include primary packaging for private-label products, packaged imported goods, counter and takeaway packaging used in retail or food service, packaging used for bakery goods, ready meals, meat, cheese, or other food products, and any other solution that comes into direct contact with food.
As a second step, the company’s PPWR role must be defined. It matters whether the company is acting as a manufacturer/producer, importer, distributor, or final distributor. The role determines the required level of documentation, conformity assessment, supplier data requests, and control processes.
As a third step, a PFAS risk screening should be carried out. Higher-risk packaging may include those providing grease-, oil-, water-, moisture-resistant, or barrier functions. Special attention should be given to coated paper and cardboard packaging, molded fiber packaging, takeaway and fast-food packaging, high-volume packaging applications, and materials where supplier documentation is incomplete or difficult to interpret.
As a fourth step, supplier information must be requested. This cannot be limited to a generic one-sentence statement. PFAS declarations, food-contact compliance documentation, material composition data, descriptions of coatings and additives, test reports, and confirmation that the supplier will notify any changes in material composition in advance may all be required.
As a fifth step, risk-based laboratory testing may also be necessary. This is particularly justified when packaging performs a high-risk function, is used in large volumes, involves imported goods, or when supplier documentation is insufficient. The testing strategy can be phased: for example, total fluorine testing, followed if necessary by clarification of whether fluorine is PFAS-related or non-PFAS-related, and then targeted PFAS analysis.
As a sixth step, compliance must be integrated into the technical documentation. PPWR conformity assessment does not involve prior regulatory approval; instead, it means that the manufacturer or relevant economic operator ensures and documents compliance under its own responsibility. The technical documentation must therefore be suitable to demonstrate, upon regulatory or business partner request, that the packaging complies with applicable requirements.
Finally, PPWR compliance should also be reflected in supplier contracts. Contracts may include clauses on PFAS limits, documentation transfer, laboratory results, change notification, liability, and indemnification. Compliance is not a one-off data request, but an ongoing supply chain management task.
Why you should not wait until the last minute
August 2026 is closer than it may seem at first. Packaging redesign, sourcing alternative materials, collecting supplier documentation, organizing laboratory testing, verifying compliance for food-contact materials, and updating contractual terms are all time-consuming processes.
Moreover, replacing PFAS is not always a simple material substitution. If a packaging solution has previously relied on PFAS-based coatings for grease or water resistance, the alternative must still meet food safety, functional performance, shelf-life, logistics, and recyclability requirements.
Companies therefore need to ask not only “Does the packaging contain PFAS?”, but also “Can we prove this?”, “What data do we have from each supplier?”, “What happens if documentation is incomplete?”, and “Do we have a plan if a packaging solution does not comply?”
The wrong approach is not asking questions. The wrong approach is discovering in August 2026 that there is insufficient information about one’s own packaging portfolio.
PFAS as a test of sustainable packaging
The PFAS story clearly shows that sustainability does not end with recycling. The environmental performance of packaging is not determined solely by how much material it uses, whether it is recyclable, or whether it contains recycled content. Equally important is what chemicals it contains, how these behave during use, waste treatment, and recycling, and whether they pose long-term environmental or health risks.
The PFAS contamination detected on Fair Isle is a warning example: “forever chemicals” do not respect geographical boundaries and do not necessarily remain at their original point of use. The PPWR provides a concrete regulatory response to this issue in the packaging sector. Not a complete solution to all PFAS risks, but a clear regulatory message: the chemical safety of food-contact packaging is an inseparable part of sustainable packaging.
For companies, this is both a challenge and an opportunity. A challenge, because compliance requires data, documentation, supplier collaboration, and often technological changes. An opportunity, because those who identify their risks early, build a more transparent packaging portfolio, and choose demonstrably safer solutions can not only ensure regulatory compliance, but also gain reputational and business advantages.
PPWR compliance creates different tasks for different companies, depending on packaging types, corporate roles, and supply chain complexity. The Planet Fanatics’ Network Ltd. team helps identify the relevant scope, define the key actions, and plan the next steps of preparation.