From 12 August 2026, food contact packaging that contains PFAS above the limits defined by the PPWR may no longer be placed on the EU market - with no transitional period for existing stock. For packaging owners, purchasing managers and compliance teams this means: anyone who cannot present complete PFAS documentation during an audit risks sales bans and fines.

But what exactly do authorities and retail partners expect? Which pieces of evidence do you need to have ready for each packaging type? And how do you build a central chemicals database that remains audit-proof even for portfolios with 1,000+ items?

This guide walks you through the process step by step - from regulatory limits and the structure of robust documentation to the digital system that ties everything together. As a practical follow-up to our overview on PFAS compliance documentation for PPWR and REACH audits, this article focuses on the hands-on setup of your central PFAS evidence database.

Overview of PPWR PFAS limits

Before you design your documentation, you should be familiar with the applicable thresholds. The PPWR sets specific PFAS limits for food contact packaging for the first time - using three graduated measurement values:

Taken together, these three limits form a tiered testing system. Manufacturers must issue an EU Declaration of Conformity and maintain technical documentation proving compliance with all thresholds. If the overall fluorine content exceeds 50 ppm, suppliers must, upon request, demonstrate how much of this is attributable to PFAS and how much to non-PFAS sources.

Why standard documentation is no longer enough

Until now, many companies have relied on generic safety data sheets or broad supplier certificates. In practice, the PPWR reverses the burden of proof - as the party placing products on the market, you must proactively demonstrate that your packaging is compliant.

In concrete terms, this means:

  • Generic statements are not sufficient: A catch-all certificate like "Our products comply with all applicable regulations" will not stand up in an audit. You need explicit PFAS statements for each material and item number.
  • Documentation per packaging type: Each Declaration of Conformity applies to one packaging type - a company with 50 formats needs 50 separate declarations, each with its own supporting documentation.
  • Retention obligations: Technical documentation must be retained for 5 years for single-use packaging and 10 years for reusable packaging.

For companies with extensive packaging portfolios, it quickly becomes clear: without a central chemicals database, this volume of documentation can neither be built nor maintained efficiently.

The central PFAS chemicals database: your foundation for audit security

The key to reliable PFAS compliance is a structured, central data backbone. Such a chemicals database connects packaging specifications, supplier data, laboratory results and Declarations of Conformity in a single system.

What an audit-proof database must deliver

  • Complete material capture: Every packaging item is documented with all layers, substrates, coatings, adhesives and barrier materials - not just the final format.
  • Item-level PFAS mapping: Laboratory results and supplier declarations are linked precisely to item numbers, specifications and material codes.
  • Versioning and change tracking: Every change to a formulation or supplier is recorded and triggers a reassessment. Auditors will ask: Which version was valid when, and for which batch?
  • Link to the Declaration of Conformity (DoC): PFAS evidence feeds directly into the PPWR Declaration of Conformity and is accessible at any time.

Why Excel reaches its limits here

With 50 or even 100 packaging types, a spreadsheet solution might just about work. But for portfolios with 1,000+ items, multiple suppliers per format and regular material changes, Excel becomes a source of risk:

  • No automatic version control
  • No systematic change tracking when suppliers or specifications change
  • No robust linking between lab result, specification and DoC
  • Manual error risks every time data is updated

A dedicated packaging management software solves exactly these problems: it digitises specifications, manages supplier declarations centrally, flags data gaps automatically and generates audit-ready evidence chains.

6 steps to audit-proof PFAS documentation

Building robust PFAS documentation follows a clear process. A risk-based approach is crucial: not every packaging item has to be lab-tested - but every item needs documented proof.

Check your audit readiness: interactive self-assessment

How well is your PFAS documentation already set up? With the following self-assessment, you can identify critical gaps in your documentation system in just a few minutes:

How Packa supports the setup of your PFAS evidence database

Systematically building a central chemicals database requires a tool that brings together packaging data, supplier communication and compliance evidence in a single platform. This is exactly where Packa comes in:

  • AI-supported specification digitisation: Packa imports existing packaging data from Excel, CSV, PDFs or ERP exports and structures it automatically - including material layers and coatings.
  • Centralised supplier communication: Through the platform, you request standardised PFAS declarations from suppliers, track responses and archive everything at item level.
  • Data gap analysis: Packa automatically identifies where PFAS evidence is missing or outdated - typically affecting 30-70% of data in the portfolio.
  • Expert validation: Imported specifications are reviewed and validated by experts to ensure data quality is audit-ready.
  • Link to DoC and compliance checks: All PFAS evidence is directly connected to the Declaration of Conformity and feeds into automated compliance checks.

Companies that are already preparing their PPWR compliance in a structured way benefit from the fact that PFAS data can be seamlessly integrated into the existing compliance framework.

Conclusion: act now, before the audit arrives

The PPWR PFAS documentation requirements will be legally binding from August 2026. Experience shows that material qualification, supplier changes and building a central database all take months. Those who only react once the first authority request comes in are already on the back foot.

Your next steps:

  1. Start with an inventory: Identify all food contact packaging in your portfolio that carries a PFAS risk.
  2. Set up your data infrastructure: Choose a central system instead of scattered individual documents.
  3. Establish your supplier process: Start now with standardised PFAS requests to all relevant suppliers.
  4. Update regularly: PFAS compliance is not a one-off project but an ongoing process with change tracking and revalidation.

Deepen your understanding of the regulatory basics in our article on the PFAS ban 2026 or learn more about current compliance requirements in our free packaging webinars.

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