Europe Restricts PFAS in Packaging, New Regulations To Take Effect in 2026

According to reports, at the beginning of 2025, a survey showed that over 90% of pulp-molded tableware products in China had excessive total fluorine content. If compared to relevant EU standards, the levels far exceeded the limit, with the highest reaching 16.6 times the limit.

On January 22, 2025, the European Union officially released the "Packaging and Packaging Waste Regulation," Regulation (EU) 2025/40, which came into effect on February 11, 2025. According to the regulation, it will be fully implemented starting August 12, 2026, simultaneously repealing the old directive 94/62/EC that had been in use for nearly 30 years. One of the most closely watched provisions is related to perfluoroalkyl and polyfluoroalkyl substances (PFAS).

PFAS are a class of fluorinated organic compounds that have been widely used for a long time due to their excellent water-repellent, oil-repellent, and high-temperature-resistant properties. They are commonly found in food contact materials (such as greaseproof paper and fast food box linings), cosmetics (waterproof mascara, foundation), textiles (coatings for outdoor clothing), non-stick cookware, fire-fighting foams, and more. However, PFAS are extremely difficult to degrade in the natural environment and can persistently accumulate in the human body and ecosystems. Numerous studies have confirmed their association with endocrine disruption, liver and kidney damage, immune suppression, and even increased cancer risk. For this reason, the European Union has listed them as "substances of concern" for priority regulation.

According to Article 5 of the EU PPWR, from August 12, 2026, all packaging materials used in food contact must comply with the following: the content of each PFAS substance must not exceed 25 ppb (parts per billion); the total content of all PFAS must not exceed 250 ppb; and the total PFAS content calculated as fluorine must not exceed 50 ppm (parts per million). Additionally, if the total fluorine content in the packaging exceeds 50 ppm, manufacturers or importers must provide their downstream customers with evidence of fluorine content from PFAS or non-PFAS sources, ensuring traceability and verifiability.

The EU is not alone; PFAS restrictions are becoming a global trend. In April 2024, the U.S. Food and Drug Administration (FDA) announced that PFAS-containing food contact greaseproof materials would no longer be sold in the U.S. Minnesota, Colorado, and other states have already banned the use of PFAS in food packaging; Japan banned 138 types of perfluorinated compounds starting January 10, 2025; France will prohibit the sale of PFAS-containing cosmetics and textiles from 2026. China has already implemented bans or strict restrictions on typical perfluorinated compounds like PFOS, PFOA, and PFHxS, but has not completely prohibited all PFAS.

What risks do Chinese companies face? If packaging is found to exceed PFAS limits, products may be denied entry, recalled, or destroyed. Many companies have not yet identified whether their packaging contains PFAS (such as greaseproof coatings, adhesives, inks). Environmental compliance has already become a core procurement standard for international buyers, such as IKEA, Nestlé, and LVMH.

Notably, PFAS may be present in seemingly "ordinary" packaging: greaseproof coatings inside kraft paper bags; coffee filters and tea bags; frozen food cartons; fast food trays and baking paper, all of which fall under the "food contact packaging" explicitly covered by PPWR.

So, how should companies proactively respond? The key is to require all packaging suppliers to provide PFAS-free statements, conduct third-party testing for high-risk materials (paper products, composite films, coatings); adopt fluorine-free greaseproof technologies (such as starch-based, chitosan, or PLA coatings); choose compostable packaging certified by OK Compost, TÜV Austria, etc.; and cooperate with organizations like SGS, TÜV, and CTI for compliance assessments.

The implementation of PPWR is not only an upgrade to environmental regulations but also a signal of the restructuring of the global consumer goods value chain. Whoever can take the lead in achieving green packaging transformation that is "PFAS-free, recyclable, and reduced in volume" will secure access to high-end markets in the EU and globally.

The countdown to August 12, 2026, has begun. Now is the best time to take action.