Short answer: From 12 August 2026, food-contact packaging may not be placed on the market at or above the PFAS concentration limits in Article 5(5), unless the placing on the market is prohibited under another Union act. The evidence plan must address the finished food-contact packaging—not only one base material.
The PPWR thresholds
Article 5(5) specifies limits for an individually measured PFAS, the sum of PFAS measured as the sum of targeted analysis, and PFAS including polymeric PFAS. The Regulation also explains how total fluorine above the specified level is treated: the manufacturer, importer or downstream user must provide proof of the fluorine content measured as either PFAS or non-PFAS.
Define the packaging scope first
Map every food-contact component and relevant substance source: substrate, barrier, coating, ink, adhesive, sealant and processing aid. Record the exact packaging version, supplier and intended food-contact use. A declaration for an unprinted substrate does not automatically cover the finished converted pack.
Build an evidence hierarchy
- Controlled composition and supplier declarations with a defined PFAS scope.
- Process and formulation knowledge covering relevant components.
- Targeted analytical evidence where needed.
- Total-fluorine investigation and explanation where triggered.
- A documented conclusion linked to the current packaging version.
Avoid unsupported claims
Terms such as “PFAS free”, “no intentionally added PFAS” and “below PPWR limits” do not mean the same thing. Record the exact claim, definition, evidence method, detection capability and exclusions. The technical documentation should explain why the selected evidence is appropriate.
Change control
Review the position when formulations, coatings, inks, adhesives, suppliers, production sites or analytical methods change. A supplier confirmation without change notification can become obsolete while still appearing current in the file.