Imagine this: your sustainability report is complete, the auditor is reviewing it - and then it turns out the PFAS data for your packaging is missing. The result: follow-up questions, delays, and in the worst case, a report that cannot be certified. This is exactly what threatens FMCG companies that still treat PPWR compliance and CSRD reporting as two separate tasks.
From 12 August 2026, both the PPWR PFAS ban and the expanded CSRD reporting obligations will apply - and both rely on exactly the same data foundation. If you start building a structured packaging data set now, you can meet both requirements with one continuous process.
This guide explains which PFAS data you need for a CSRD-compliant sustainability report, how to leverage the interface with the PPWR, and how digital packaging management can significantly reduce the effort involved.
Why PFAS appears in the CSRD sustainability report
The CSRD (Corporate Sustainability Reporting Directive) requires affected companies to structure their sustainability reporting according to the European Sustainability Reporting Standards (ESRS). A total of 12 ESRS standards cover environmental, social and governance topics - one of which is particularly relevant for packaging owners.
ESRS E2 governs reporting on pollution - especially pollution of air, water and soil, as well as substances of concern. This is where PFAS comes into play: as per- and polyfluorinated alkyl substances, they are classified as substances of concern (SoC) and are therefore subject to the ESRS E2-5 disclosure requirement.
The ESRS E2-5 disclosure requirement covers information on the production, use, distribution, marketing and import or export of substances of concern and substances of very high concern - whether in pure form, in mixtures or in articles.
For FMCG companies, this means in concrete terms: if you use - or have used - packaging made with PFAS-containing materials, you must report on this transparently in your sustainability report, including quantities, risks, measures and targets.
The principle of double materiality
The CSRD is based on the principle of double materiality. As with climate change, the assessment of double materiality is also decisive for pollution. Companies must determine whether their business activities cause significant pollution, or whether they are exposed to risks associated with such pollution.
For FMCG companies with food contact packaging, PFAS is very likely to be material under ESRS E2 - both from an impact perspective (release of harmful substances into the environment) and from a financial perspective (market exclusion risks due to the PPWR ban from August 2026).
At the same time, companies must be able to clearly demonstrate how they collected specific ESG data and how ESRS KPIs were derived. Sustainability metrics are therefore on an equal footing with other mandatory information from financial reporting.
The interface: Using PPWR PFAS data directly for ESRS E2
This is where the biggest efficiency gain lies for packaging owners: the data you need for the PPWR declaration of conformity is almost identical to the data that underpins your ESRS E2 reporting. You do not need to collect this information twice - provided you build the right data structure.
What the PPWR requires for PFAS
From 12 August 2026, food contact packaging may no longer contain PFAS above a concentration of 25 ppb (individual PFAS), 250 ppb (sum of PFAS) or 50 ppm (total fluorine content including polymeric PFAS). According to the EU guidance, there is no transition period to run down existing stock. Any packaging with a total PFAS content above 50 milligrams per kilogram may no longer be placed on the market after the cut-off date - even if it was produced beforehand.
The European Commission recommends a three-step testing protocol: first, total fluorine quantification (Total Fluorine). If the measured TF value is below 50 mg/kg, the sample is considered fully compliant - not only with the 50 ppm limit, but automatically also for the more complex testing steps 2 and 3. Further tests are not required in this case.
What ESRS E2 requires in addition
Companies must report, in line with specific EU regulations, on pollutants they emit through their own activities, as well as on microplastics that are generated or used. They must also disclose information about the production, use, distribution, marketing and import/export of (very) high-concern substances in mixtures or articles.
For packaging owners, this means: you need not only the screening values (PPWR), but also structured data on which products, in which markets, and in what quantities PFAS has been used - or eliminated through substitution.
The critical data gap: Why many companies are now falling behind
In most FMCG companies, the reality is this: packaging data is fragmented across Excel sheets, PDF supplier documents and ERP exports. A central, structured database for substance information is often missing.
Experience from practice shows that when packaging portfolios are systematically reviewed, typically 30 to 70% of the relevant substance and material data required for ESRS E2-compliant reporting is missing. This is not an exception - it is the norm.
Three common data gaps that block CSRD reporting:
- Missing substance information: For many packaging components, there is no structured data on chemicals, coatings or additives.
- Incomplete supplier documentation: PFAS screening data is not consolidated across suppliers, or cannot be linked at article level.
- Missing quantity data: Under ESRS E2, you must report quantities of substances of concern in appropriate units (e.g. tonnes or kilograms) - which requires packaging weights, material shares and sales volumes per packaging type.
The consequence: If you do not start collecting this data in a structured way now, you will not be able to demonstrate compliance with the PPWR PFAS ban, nor will you be able to produce a CSRD report that stands up to audit.
Your 6-step plan: Preparing PFAS data for CSRD compliance
How to assess your current PFAS-CSRD readiness
Use this interactive self-check to assess your current level of readiness:
The data structure your ESRS E2 PFAS report needs
An ESRS E2-compliant sustainability report on substances of concern in packaging requires the following data points:
Quantitative information:
- Total quantity of PFAS-containing packaging materials (in kg or tonnes per reporting year)
- Number of packaging items that fall under the PPWR PFAS ban
- Share of packaging for which PFAS screening evidence is available
Qualitative information:
- Description of your policy on the use of substances of concern
- Materiality assessment and rationale (ESRS E2-2)
- Measures taken to substitute PFAS and their implementation status
- Quantitative targets (e.g. "PFAS-free food packaging by August 2026")
- Description of risk monitoring across the supply chain
For external assurance: Non-financial sustainability information is also subject to external assurance. Companies must demonstrate in a transparent way how they collected ESG data and how ESRS KPIs were derived. For each data point, document the collection method, data source and any estimation assumptions.
Do not forget ESRS E5: Recyclability and circular economy
In addition to ESRS E2, ESRS E5 (resource use & circular economy) is also relevant for packaging owners. ESRS E5 sets reporting requirements for resource use and the circular economy - in particular for materials and their circular use, the company's products and their circular use options, as well as waste.
Recyclability rates, recycled content shares and packaging waste volumes - you must also have these data points under control for a complete ESG report. You can find more details on PPWR updates and recyclability requirements on our blog.
Digital packaging management as the foundation for CSRD-compliant ESG reporting
Manually piecing together PFAS data from different sources is error-prone, time-consuming and not scalable - especially when you are dealing with hundreds or thousands of packaging items. The solution: a central packaging management platform that supports PPWR compliance and CSRD reporting from a single data foundation.
The Packa software supports packaging owners on several levels:
Central data foundation for all packaging items:
- AI-supported digitization of packaging specifications from Excel, PDF, CSV and ERP exports
- Structured capture of material compositions, chemical information and supplier data at article level
- Automatic identification of data gaps - typically 30-70% missing data becomes visible this way
Automated compliance checks:
- Automatic comparison of PFAS values with PPWR thresholds (25 ppb, 250 ppb, 50 ppm)
- Documentation of all test results in an audit-ready format
- Structured supplier communication to obtain missing evidence
CSRD-ready reporting:
- Consolidation of substance and quantity data for ESRS E2-5
- Audit-ready documentation of all data sources, test methods and timestamps
- Reports that can be used both for PPWR declarations of conformity and for ESG sustainability reports
The timing challenge: CSRD and PPWR are running in parallel
The CSRD introduces the new reporting obligations in phases. For companies already subject to reporting requirements under the Non-Financial Reporting Directive (NFRD), the application begins with the management report published in 2025. Waves 2 and 3: the application of the CSRD for other large companies and SMEs has been postponed by two years - Wave 2 (large companies) covers the 2027 reporting year with first publication in 2028; Wave 3 (listed SMEs) covers the 2028 reporting year with first publication in 2029.
This means that for many mid-sized FMCG companies, CSRD reporting obligations will start in parallel with the PPWR roll-out. If you start building a PFAS-compliant data foundation now, you will be preparing simultaneously for the PPWR (August 2026) and the upcoming CSRD reporting years.
Your action plan as a packaging owner:
- Now: Take stock of all packaging items and identify data gaps relating to substance information
- By August 2026: Collect PFAS screening data in full and create PPWR declarations of conformity
- Ongoing: Maintain the data foundation for ESRS E2-5 and ESRS E5 and keep it up to date for upcoming reporting years
You can find a detailed overview of PFAS compliance strategies for FMCG companies and of supplier communication for PFAS data 2026 in our expert articles.
Conclusion: Double the value from one structured data foundation
PFAS in packaging is no longer a stand-alone topic - it sits at the intersection of product regulation (PPWR), ESG reporting (CSRD/ESRS E2) and long-term supplier responsibility. Companies that now invest in a structured, digital packaging data foundation can meet both requirements with a single process, while also creating the basis for future regulatory demands.
Assess today: Which of your packaging items are PFAS-relevant? For which ones is screening data still missing? And: what percentage of your substance data is already available in a format that can withstand external audit?
The answers to these questions will determine whether your next sustainability report is compliant - or not.
