PPWR PFAS limits overview
- PPWR now restricts PFAS levels in packaging across Europe
- Packaging exceeding PFAS limits risks enforcement action and restrictions
- Manufacturers should prevent contamination through materials, coatings and processes
- Member States will monitor PFAS compliance until harmonised testing arrives
- PFAS-free alternatives can deliver grease resistance and regulatory compliance
On 12 August, the Packaging and Packaging Waste Regulation (PPWR) became enforceable. While many of its key provisions will only be relevant at a later date, the regulation’s limits on PFAS in packaging are applicable already.
Manufacturers must ensure that the presence of PFAS in packaging is kept below these limits.
What are PFAS?
Per-and polyfluoroalkyl substances, or PFAS, are chemicals, which are used to repel water and oil, as well as resist heat. While they are very useful on a functional basis, and are therefore widespread in packaging and cookware, they have been linked to a number of adverse health effects, including thyroid disease, fertility issues, liver damage, and some types of cancer. They are known as 'forever chemicals' because, due to their very strong bonds, they do not degrade in the environment for thousands of years. They can contaminate food through contact.
What are the PPWR’s PFAS limits?
By the strictures of the PPWR, the presence of PFAS in packaging is now limited to 50 parts per million (ppm) when used in polymeric PFAS, 250 parts per billion (ppb) for the sum total of non-polymeric PFAS, and 25 ppb for each individual type of non-polymeric PFAS when detected by targeted PFAS analysis.
Non-polymeric PFAS are smaller than polymeric PFAS, as well as more reactive, and considered more harmful, according to the University of Rhode Island.
A harmonised testing approach for PFAS is currently being developed. Before this, Member States will monitor compliance through national authorities.
Penalties for infringing the regulation are delegated to Member States. The deadline for penalties being developed is 12 February 2027. According to the PPWR FAQs, those who infringe the regulation will receive a warning before any penalty.
In the period between now and 12 February, manufacturers infringing the regulation may be denied market access, explains Manon Ombredane, director of environment, health and safety practice at law firm Squire Patton Boggs.
“First and foremost, the PPWR is a market-access regulation. Accordingly, even in the absence of specific national penalty regimes, market surveillance authorities may still take enforcement measures against non-compliant packaging, including restricting its placing on the market, requiring corrective action, or ordering its withdrawal or recall where appropriate.”
How PFAS gets into packaging
PFAS get into packaging through a variety of means.
They can get into or onto packaging through the chemicals used to manufacture it, explains Roger Wright, waste strategy and packaging manager at waste management company Biffa. They can also be physically present as a coating on or in said packaging.
Secondary PFAS can contaminate paper packaging through the recycling process. Industrial machines can even use PFAS to eject packaging from its moulds.
Once PFAS are in fibre-based packaging, they cannot be removed. They form very strong bonds that are locked into the fibre itself and can’t be washed or dissolved away.
Therefore, manufacturers must ensure that PFAS do not get into packaging in the first place.
How can PFAS be kept out of packaging?
It is possible for manufacturers to avoid putting PFAS in packaging.
Firstly, they can avoid the use of coatings that contain intentionally added PFAS, instead using certified PFAS-free raw materials, explains Biffa’s Wright.
Manufacturers can use materials that are processed to mimic the performance of PFAS-coated packaging. This can be done by mechanically supercalendering (a process that gives a high gloss to paper) or pressing fibres tightly together.
Alternatively, manufacturers could apply a natural degradable coating like starch, seaweed or natural waxes to mimic required grease or moisture-resistant properties.
For recycled materials, food companies should aim to isolate and manage inputs better.
Fibre-based and other porous materials are particularly susceptible to contamination by PFAS, says Wright. Fibre-based fast food wrappers, microwavable bags and baking papers all have historically used a type of PFAS to ensure functionality.
Materials that have lower risk of contamination include virgin and recycled plastic products made from PET, PP or HDPE, glass, metal or aluminium. These materials are “entirely immune to PFAS absorption”, says Wright. Alternatively, fibre-based packaging with natural PFAS-free coatings could be used.
If companies are to comply with the PPWR, they must do whatever they can to reduce PFAS in packaging, and fast. Time is of the essence.
