PFAS Compliance in Packaging Management: What Documentation You Need for PPWR and REACH Audits in 2026

Companies that place food packaging on the EU market will soon have to fully demonstrate and document PFAS risks. This article explains which records are required for PPWR compliance and REACH compliance, how to set up supplier declarations, PFAS evidence, and change tracking in a structured way, and why digital packaging management will become the backbone of your PFAS documentation.

Executive Summary

From 12 August 2026, food-contact packaging containing PFAS above the limit values defined in the PPWR may no longer be placed on the market in the EU. At the same time, REACH requirements are tightening, with existing PFAS restrictions and the planned universal restriction.

Being audit-ready requires transparent, traceable PFAS documentation - from extended material lists and explicit PFAS-free supplier declarations to REACH evidence and consistent change tracking. This article structures the requirements and offers a practical roadmap for regulatory affairs, procurement, and supply chain teams.

1. Regulatory framework: PFAS under PPWR and REACH

1.1 PFAS in food-contact packaging: PPWR as a market access gatekeeper

The Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) has been in force since February 2025 and will apply from 12 August 2026 to all packaging placed on the EU market.It replaces the previous Packaging Directive and makes substance restrictions - including PFAS - directly binding.

Relevant for PFAS:

• Scope: Food-contact packaging (Food Contact Materials, FCM)
• Principle: No PFAS above the defined sum limits in food-contact packaging that is placed on the market for the first time from 12 August 2026 onwards. Stock produced earlier but only sold after this date must also comply with these requirements
• Definition: PFAS includes any substance with at least one fully fluorinated methyl or methylene carbon according to the PPWR. The PPWR uses a structure-based definition, aligned with current scientific and regulatory discussions on a "universal" PFAS restriction

For companies, these requirements interact with what is often loosely called "food packaging law": a combination of PPWR, general food law, specific FCM rules, and national chemicals legislation.

1.2 REACH: PFAS as substances of very high concern (SVHC)

Independently of the PPWR, the REACH Regulation (EC) No. 1907/2006 regulates PFAS on several levels:

• SVHC Candidate List: Many PFAS are listed as Substances of Very High Concern.
• Information obligation: If an SVHC is present in an article (e.g. a packaging component) at > 0.1% by weight (w/w), information obligations along the supply chain apply under Article 33 REACH.
• Restrictions: Individual PFAS are already restricted under Annex XVII, with more to follow.
• Universal restriction: A broad PFAS restriction under REACH is in preparation and foresees only a few, time-limited exemptions for "essential use".

Crucially: PPWR compliance does not automatically guarantee REACH compliance. You must consider both frameworks in parallel.

2. What auditors want to see: Core requirements for PFAS documentation

Audits - by authorities, retailers, or customers - primarily assess the systematic approach behind your evidence chain. The key question: Can you demonstrate that your packaging complies with PPWR and REACH, and that all changes have been fully documented?

2.1 Explicit PFAS-free statements instead of generic safety data sheets

For PPWR-relevant food-contact packaging, standard safety data sheets are not sufficient. Auditors expect:

• Explicit PFAS statements for each material or specification (e.g. "PFAS-free according to PPWR definition / below limit value")
• Clear reference to the covered item numbers, material codes, or specifications
• Date and version information for each declaration
• Reference to test reports or assessment methods (e.g. risk-based assessment / laboratory analysis)

For every packaging specification, there should be a complete "document package" that links PFAS evidence, material structure, and supplier data.

2.2 Structured supplier declarations

A robust supplier declaration on PFAS includes:

• Clear identification of the supplier, site, and contact person
• Allocation to specific materials/items
• Statement on PPWR compliance (e.g. no intentionally added PFAS according to the definition, limit values respected)
• Statement on REACH compliance (e.g. no PFAS SVHC > 0.1% or listing of any affected substances)
• Period of validity and/or a note that the declaration will be renewed if changes occur

Supplier declarations are snapshots in time. Without consistent change management, their value in an audit rapidly diminishes.

2.3 Change tracking: Recording formulation changes in an audit-proof way

Suppliers change formulations, raw materials, or coatings - often without explicitly flagging PFAS. Therefore:

• Every relevant formulation change must be captured, assessed, and documented.
• Previous PFAS-free declarations then cease to be valid; a new assessment (with a new supplier declaration and, where appropriate, laboratory testing) becomes necessary.
• Changes must be traceable: Which version applied when, and to which batch?

Without systematic change tracking, audit gaps are virtually guaranteed.

3. PPWR-specific documentation obligations for PFAS in food-contact packaging

The PPWR requires a conformity assessment and a PPWR Declaration of Conformity (DoC) for each type of packaging. PFAS is one element within a broader context of design, recycling, and substance requirements.

3.1 PPWR DoC: The role of PFAS in the technical dossier

From 12 August 2026, every packaging placed on the EU market needs a PPWR Declaration of Conformity. The DoC refers to a technical documentation file that should cover at least the following elements:

• Detailed packaging inventory with unique identification
• Complete material structure (layers, coatings, adhesives)
• Assessment of PFAS conformity (e.g. risk-based assessment, lab reports)
• Key supplier declarations and test reports
• Documentation of assessment methods and applied limit values

You can find more on the structure of a PPWR DoC in the packaging managers' guide here.

3.2 Retention periods and audit readiness

Technical documentation and PPWR Declarations of Conformity must be kept for at least five years (single-use packaging) or ten years (reusable packaging). Over the same period, the following PFAS-related documents must be stored in an audit-proof manner:

• PFAS test reports
• PFAS-related supplier declarations
• Change history (formulation changes or supplier switches)

3.3 Interface with food law

The PPWR complements existing food-contact regulations (e.g. the EU Framework Regulation, national food and feed codes) but does not replace them. In practice this means:

• PPWR regulates packaging design, substance restrictions (including PFAS), and recyclability.
• Food law standards secure health protection and migration limits.

Your documentation should link both layers - ideally in a single digital packaging dossier per specification.

4. REACH compliance: PFAS documentation beyond packaging

4.1 REACH documentation obligations for PFAS

REACH triggers documentation and information obligations where PFAS is concerned:

• Information obligation under Article 33 REACH:
  • B2B customers must be informed if an SVHC (e.g. PFAS) is present at > 0.1% w/w.
  • End consumers are entitled to this information upon request. The threshold applies to each individual component of a complex article (e.g. label, closure, coating).
• Notification obligations to databases (e.g. SCIP), if SVHCs are used.

REACH compliance documentation typically includes:

• REACH-compliant supplier declarations (e.g. "REACH Candidate List as of [date] checked")
• Safety data sheets and information on hazardous substances
• Internal assessment documents (affected articles, quantities, customers)

4.2 Dual-framework complexity: PPWR vs. REACH

A typical challenge:

• A material is PPWR compliant - no intentionally added PFAS, limit values respected - but REACH obligations can still arise if PFAS SVHC > 0.1% is present as a residual or impurity.

Your documentation therefore needs to distinguish between PPWR and REACH perspectives, while systematically linking them.

5. Comparison: Documentation requirements for PFAS under PPWR vs. REACH

6. Operational implementation: Processes for PFAS evidence, change tracking, and audit readiness

6.1 Data foundation: Extended material lists in packaging management

PFAS compliance is primarily a data challenge:

• Many PFAS are not part of the base material but appear in coatings, adhesives, or processing aids.
• Without complete material and layer lists ("extended material lists"), these components remain invisible.

Packa recommends basing PFAS risk assessments for each specification on data for: base material, layer structure, functional coatings, adhesives, and barrier layers.

Practical tip: Maintain a digital data sheet for every packaging specification that includes:

• Substrate (e.g. paper, PET, PE, PP)
• Full layer build-up
• Functional properties (e.g. grease barrier, non-stick)
• Supplier, plant, and item numbers

6.2 Structured supplier declarations and PFAS evidence

For scalable PFAS documentation, you need the following elements in supplier management:

• Standardised questionnaires on PFAS use and REACH status
• Clear requirements for the format of supplier declarations (content, validity, link to the specification)
• Criteria for when laboratory analysis is appropriate (e.g. grease-resistant papers, functional coatings)

This creates a repeatable, audit-proof routine.

6.3 Change management: From formulation change to updated PFAS evidence

A reliable process defines the following triggers for a reassessment:

• Formulation or product change at the supplier
• Change of raw material source
• Legal changes (e.g. new PFAS SVHC added to the Candidate List)

Each trigger starts a workflow:

1. Change notification from the supplier
2. Update of the specification/material list
3. Assessment of PFAS risk
4. New evidence (supplier declaration, and lab test where necessary)
5. Documentation in the technical dossier and, if applicable, update of the PPWR DoC

6.4 Monitoring the REACH Candidate List and PFAS updates

The REACH Candidate List continues to grow, including in the PFAS area. Each addition can turn previously uncritical materials into SVHC-relevant ones.

Recommendations:

• Use regulatory monitoring tools or specialised service providers
• Regular comparison of the Candidate List with your substance lists
• Documented assessment for every update (affected articles, customers, obligations)

6.5 Use digital systems and automation

Manual Excel lists and email attachments quickly reach their limits when you manage many specifications. Digital packaging management software makes evidence management and audit preparation significantly easier.

Typical functionalities:

• Central, version-controlled specification and document management
• Linking packaging items to their PPWR DoCs and PFAS evidence
• Workflows for supplier requests and change management
• Analytics for PPWR and REACH compliance across the portfolio

You can find more in the article "PPWR compliance without chaos" here and in the PPWR checklist here.

7. Checklist: What documents do you need for PFAS audits?

The following overview helps you identify gaps in your PFAS documentation.

7.1 For PPWR compliance (food-contact packaging)

• Complete list of all food-contact packaging (SKUs, specifications)
• Extended material lists including coatings, adhesives, and layers
• Risk classification for each packaging type
• PFAS-related supplier declarations for each material/specification
• PFAS lab reports where needed for high-risk packaging
• Assessment methodology (e.g. risk-based)
• Complete PPWR DoC for each packaging type with PFAS references
• Documented change management (versioning, history)

7.2 For REACH compliance

• List of PFAS-relevant substances/mixtures used
• Comparison with the current REACH Candidate List
• REACH-compliant supplier declarations including Candidate List status
• Evidence of information passed on (Article 33 REACH)
• Where applicable, registry entries (e.g. SCIP)

7.3 Cross-functional governance

• Clear responsibilities (regulatory affairs, procurement, quality, R&D)
• Training on PFAS risks and documentation requirements
• Regular reviews of the PFAS strategy

Further background on PFAS regulation in packaging can be found in the article "PFAS in packaging: What companies need to know by 2026" here and in the PFAS topic overview here.

8. Conclusion and next steps

PFAS compliance in packaging management requires sustainably maintained documentation that consistently reflects PPWR and REACH requirements.

Recommended next steps for decision-makers:

1. Status analysis: Identify food-contact packaging with PFAS risk. What data and evidence do you already have?
2. Build a data structure: Maintain extended material lists and central specification data.
3. Standardise supplier processes (questionnaires, supplier declarations, testing concepts).
4. Launch a PPWR DoC programme: Define the structure and content of the technical documentation and run a pilot.
5. Establish REACH monitoring: Systematically track Candidate Lists and upcoming PFAS restrictions.
6. Leverage digitalisation: Evaluate which digital systems can efficiently support PFAS and PPWR documentation.

Those who address these points early can turn PFAS regulation into a competitive advantage: faster audits, lower market access risk, and transparent packaging data for procurement, quality, regulatory affairs, and sales.

Frequently Asked Questions

How important is the supplier declaration for PFAS compliance?

The supplier declaration is crucial, but not sufficient on its own. It documents the supplier's self-assessment and forms the starting point for your own evaluation. For high-risk applications (e.g. grease-resistant FCM), supplier declarations alone are not enough - you should complement them with targeted laboratory analysis and detailed material data.

Do all food packaging products have to be tested for PFAS?

No. Blanket lab testing of all SKUs is neither economically nor practically viable. The industry standard is a risk-based approach: you identify high-risk applications (e.g. fat or oil barriers) and prioritise them for lab tests. For low-risk packaging, structured supplier declarations and material data are often sufficient.

How long must PFAS documents be retained?

The key reference is the retention period for PPWR documentation: at least five years for single-use and ten years for reusable packaging after placing on the market. Because of potential liability issues, many companies choose to retain PFAS documents for at least these periods and often longer.

What is the difference between PPWR and REACH compliance for PFAS?

• PPWR compliance governs the conformity of packaging, in particular the PFAS ban for food-contact packaging from August 2026 onwards, including DoCs and technical documentation.
• REACH compliance concerns chemicals legislation: SVHC thresholds, information and notification duties, and future PFAS restrictions.

A material may be PPWR compliant but still relevant under REACH - or vice versa. Both perspectives must be integrated into a single assessment system.

What applies to stock produced before 12 August 2026?

The decisive factor is the first placing on the market: packaging that appears on the EU market for the first time after 12 August 2026 must comply with the PPWR PFAS requirements - regardless of when it was produced. You should therefore review stock levels and supply contracts early to avoid being left with non-compliant residual inventory.