From 12 August 2026, food contact packaging containing PFAS above defined limit values may no longer be placed on the market in the EU. There is no transition period and no grandfathering for existing stock. For packaging owners in FMCG companies this means: if you do not act now, you risk fines, sales bans, and losing access to the EU market.
While other articles explain the regulatory background and the PFAS risk assessment for food packaging or PFAS documentation for audits, this article provides a concrete implementation roadmap: six steps that you and your team can systematically work through starting today.
What exactly the PFAS ban under the PPWR covers
The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) bans per- and polyfluoroalkyl substances (PFAS) in all packaging that comes into contact with food. At the end of March 2026, the European Commission published official guidelines and confirmed that there are no plans to postpone the start date. Source
Overview of PFAS limit values
If the total fluorine content exceeds 50 mg/kg, proof of origin is required. Source Crucially, marketability depends solely on the proven concentration - not on whether you intentionally use PFAS.
Who is responsible?
The company that places the packaging on the EU market for the first time is responsible - typically brand owners, manufacturers, or importers. If you source packaging from EU manufacturers, you must request the declaration of conformity from your supplier. If you manufacture yourself or import from outside the EU, you bear full responsibility. You can find more details in our guide to PPWR roles and responsibilities.
Which packaging types are most affected
Not all packaging carries the same PFAS risk. The following are particularly exposed:
- Grease-resistant paper and board packaging - for example, fast-food boxes, bakery bags, pizza boxes
- Coated trays and dishes - for meat, sausages, or ready meals
- Laminated multi-layer structures - with PFAS-containing barrier layers or adhesives
- Certain flexible plastics - where PFAS are used as processing aids
Bio-based packaging can also contain PFAS-based coatings and is therefore covered by the ban. Source
Packaging made from glass, metal, or uncoated plastics generally has a low PFAS risk - but should still be documented.
6 steps to PFAS compliance by August 2026
Most companies need 4 to 9 months for the complete transition process - from supplier sourcing and material testing through to production changeover. Source Start now to make sure you meet the deadline.
Practical tip: Take a risk-based approach
There is currently no harmonized EU test method for PFAS under the PPWR. Comprehensive testing of all packaging is neither economical nor practical. Instead, rely on a structured PFAS risk assessment: create an extended material list, assign risk categories, and send only identified high-risk formats for laboratory testing. This approach is cost-efficient, robust from a regulatory standpoint, and scalable across large portfolios.
PFAS substitutes: What the market offers
For many affected packaging formats there are already PFAS-free alternatives:
- Baking paper: PFAS have already been completely replaced by other coatings
- Grease barriers on paper/board: wax, silicone, or dispersion coatings as alternatives
- Flexible films: PFAS-free barrier coatings, for example based on polyvinyl alcohol (PVOH)
Experts estimate that PFAS-free alternatives can be found for 99 out of 100 applications. Source The challenge is less about availability and more about the systematic qualification and documentation of substitute materials - especially for large portfolios with hundreds or thousands of items.
How to assess your PFAS readiness now
Use the following self-assessment tool to evaluate your company's PFAS compliance status:
Why manual processes reach their limits for PFAS compliance
For portfolios with hundreds of packaging items, manual PFAS management in Excel quickly reaches its limits:
- Data gaps - typically 30-70% of the relevant packaging data is missing
- Supplier communication - requesting, tracking, and validating dozens of supplier declarations
- Documentation - keeping laboratory results, material declarations, and declarations of conformity ready for audits
- Tracking - maintaining up-to-date PFAS status when materials or suppliers change
With a digital platform such as Packa software, you centralize all packaging data, automate compliance checks, and generate audit-ready documentation at the touch of a button. This gives you proactive control over PFAS risks - instead of reacting after test results arrive.
Specifically, Packa supports PFAS implementation through:
- AI-supported specification digitization - automatically structuring packaging data from Excel, PDF, and ERP exports
- Automated compliance checks - identifying and monitoring PFAS risks at item level
- Integrated supplier management - requesting and managing supplier declarations and certificates digitally
- Audit-ready documentation - complete traceability of all compliance evidence
Learn in our free packaging webinars how leading companies are already digitizing their packaging management.
Conclusion: Act now before the deadline becomes a problem
The PFAS ban is not a distant piece of regulation - it comes into force in just a few months. Packaging owners who take a systematic approach now not only secure market access, but also gain a genuine competitive advantage through transparency and data sovereignty.
Your next steps:
- Start portfolio screening - identify all food contact packaging
- Prioritize high-risk formats and request evidence from suppliers
- Assess how a digital PPWR checklist can help you detect gaps
