From 12 August 2026, food-contact packaging containing PFAS above defined threshold values may no longer be placed on the market in the EU. For companies with several hundred or even thousands of packaging items, a crucial question arises: How do you efficiently check your portfolio for chemical compliance - manually or in an automated way?
The choice affects not only the time required, but also error rates, lab costs, and audit readiness. This article compares both approaches and explains when it pays off to switch to automated testing.
Why chemical screening becomes mandatory in 2026
The EU Packaging and Packaging Waste Regulation (PPWR) significantly tightens the requirements for the chemical safety of packaging. The PPWR defines three threshold values for PFAS in food-contact packaging: 25 ppb for individual PFAS substances, 250 ppb for the sum of targeted analyses, and 50 ppm for total fluorine. These values are based on Article 5 of the regulation, which calls for the minimisation of substances of concern throughout the entire life cycle of packaging.
Particularly critical: If the total fluorine concentration exceeds 50 ppm, the burden of proof shifts to the manufacturer or supplier. They must then demonstrate that the fluorine does not originate from regulated PFAS substances. Without structured screening, you risk not only fines but also a reversed documentation burden.
Beyond PFAS, the topic also covers migration testing, the assessment of NIAS (Non-Intentionally Added Substances) and further substances - a complex field that requires systematic processes. If you would like to explore the regulatory fundamentals in more detail, our article PFAS in packaging: What companies need to consider by 2026 provides an in-depth overview.
Manual chemical screening: The traditional route
With a manual approach, specialists check each packaging item individually against regulatory requirements. Typically, it looks like this:
- Research: Employees compare material specifications with current threshold values - often using Excel spreadsheets and PDF data sheets.
- Supplier queries: You request material data, declarations of conformity, and test results by email - with unclear deadlines and manual follow-up.
- Documentation: Results end up in local folders or spreadsheets - without a consistent structure or version control.
- Lab tests: Without a preselection, you either test too many or too few packaging items.
Where the manual approach reaches its limits
For small portfolios with fewer than 50 SKUs, manual screening can work. However, in larger FMCG portfolios it quickly becomes clear: Manual compliance approaches do not scale when portfolios encompass thousands of SKUs and global supply chains are involved. On top of that, PFAS analysis requires a multi-step approach - from total fluorine screening through to targeted analysis of up to 165 PFAS substances. Coordinating this manually ties up substantial resources.
Automated screening: Data-driven and scalable
Automated chemical testing relies on structured data and rule-based validation logic. Instead of researching each material individually, a digital platform captures packaging data centrally and automatically compares it against regulatory requirements.
The benefits become clear across several dimensions:
- Risk-based prioritisation: The system automatically identifies high-risk materials (e.g. grease-resistant papers, coated boards) and focuses the screening effort on them.
- Automated threshold checks: All three PPWR thresholds are checked in parallel - without manual comparison.
- Efficient supplier management: Digital forms replace email correspondence; automatic reminders help ensure a reliable response rate.
- Audit-ready documentation: Every review step is traceably documented and can be retrieved at any time.
We describe what a data-driven compliance workflow can look like in practice in our article PFAS compliance in packaging management: Which documentation you will need in 2026.
Head-to-head comparison: Manual vs. automated
5 steps to efficient chemical screening
Regardless of your organisation's current maturity level, we recommend a structured approach that sensibly combines manual and automated elements:
You can save significant time, especially in steps 1 to 3, through automation. Digital packaging management centralises your data foundation and creates the conditions to use lab testing in a targeted and cost-efficient way.
Which approach is right for your company?
Use our interactive tool for an initial assessment: Is manual screening sufficient for your portfolio - or is an automated approach the better option?
Practical example: How preselection reduces testing costs
A typical FMCG company with 2,000 packaging items and 80 suppliers would need to allocate a substantial budget if it relied solely on lab testing. PFAS laboratory analyses cost between 300 and 800 USD per sample for a comprehensive assessment.
By using risk-based preselection with automated data checks, you can drastically reduce the number of lab tests actually required:
- Without preselection: Testing all 2,000 items -> Costs: 600,000-1,600,000 USD
- With risk-based preselection: Testing only ~200-400 high-risk items -> Costs: 60,000-320,000 USD
The savings do not come from reducing safety, but from smarter prioritisation. A structured PFAS risk classification at material level enables a proportional prioritisation of screening efforts.
Conclusion: Automation is not a luxury - it is risk management
The question is not if, but when you automate your chemical checks. With the PPWR deadline in August 2026 and the growing complexity of regulatory requirements - from PFAS and BPA through to further substances that will become reportable from December 2026 onward - manual processes are no longer sufficient for most FMCG portfolios.
Your next steps:
- Identify which of your packaging items are used in food-contact applications and fall into high-risk material categories.
- Request structured material data from your suppliers - digitally, not by email.
- Assess whether your current documentation would stand up to an audit.
- Learn more about best practices in chemical compliance management in our free packaging webinars.
If you want to dive deeper into AI-enabled packaging management compared with traditional approaches, our article AI-based packaging management: Automation vs. traditional approaches provides a comprehensive analysis.
