From 12 August 2026, food-contact packaging that contains PFAS above defined threshold values may no longer be placed on the EU market - and this applies without any grandfathering for already produced stock. For FMCG companies with hundreds or thousands of packaging items, this is not an abstract regulation but a very real market access risk.

While existing articles cover the regulatory details of the PFAS ban and the PFAS documentation required for audits, this article focuses on the strategic level: How can FMCG companies move from reactive to proactive PFAS compliance - and what structures do they need to get there?

What has changed in regulation - and why time is running out

The PPWR (Regulation (EU) 2025/40) replaces the previous EU Packaging Directive with directly applicable law in all 27 Member States. On 30 March 2026, the European Commission published official guidelines and a set of FAQs on the PPWR, which serve as an interpretative aid for authorities and businesses.

For PFAS in food-contact packaging, the following threshold values apply from 12 August 2026:

Two aspects make the situation particularly urgent:

  • No grandfathering: Packaging produced before 12 August 2026 may no longer be placed on the EU market for the first time after that date if it exceeds the threshold values.
  • No harmonised test method: There is currently no single, harmonised EU test method for PFAS under the PPWR. The EU guidelines recommend a stepwise testing approach (total fluorine -> organic fluorine -> targeted analysis).

In parallel with the PPWR, requirements under REACH are also being tightened: By the end of 2026, the European Commission and ECHA must submit a report on substances of concern in packaging, which may trigger further restrictions.

Why reactive PFAS compliance fails

Many companies still address PFAS risks on a case-by-case basis: a concern arises, an ad hoc query is sent to the supplier, and the response ends up in a folder. This approach has three fundamental weaknesses:

  • Scalability: For portfolios with 1,000+ packaging items, manual individual checks are neither feasible in terms of time nor economically viable.
  • Incomplete data foundation: Typically, 30-70% of relevant packaging data is missing when it is collected systematically for the first time. Without a complete material structure per SKU, PFAS risks remain invisible.
  • Lack of audit readiness: Scattered supplier declarations, unlinked test results and missing change tracking make audit-proof documentation practically impossible.

Most food companies need four to nine months to switch to a PFAS-compliant supplier - from testing and artwork changes through to stock clean-up.

Anyone who has not yet started a structured risk analysis is already racing against the clock.

Five steps to a proactive PFAS compliance strategy

The path from reactive to proactive compliance follows a clear logic: Create transparency -> Prioritise risks -> Collect data -> Test -> Monitor continuously.

The crucial difference from ad hoc checks: you do not test everything across the board, but based on risk. Only formats identified as high risk (grease-resistant papers, coated boards, laminated multi-layer packaging) go through the laboratory testing process. This keeps the strategy cost-efficient and scalable across large portfolios.

Reactive vs. proactive: What really changes

Switching to proactive compliance is not just an IT project - it is a strategic decision that equally affects procurement, packaging engineering and quality assurance.

Why digital packaging management is now critical

PFAS compliance illustrates perfectly why Excel-based packaging management is reaching its limits. When material structure, supplier declarations, test results, compliance status and change tracking are scattered across different systems, you lose the end-to-end evidence chain.

A central packaging management platform links PFAS data directly to the declaration of conformity (DoC) and the packaging specifications. This creates a complete compliance dossier for each packaging item - ready for audit at any time.

More specifically, the Packa software supports FMCG companies in:

  • Digitising packaging specifications centrally and recording bills of materials in full, including coatings, adhesives and barrier layers
  • Automating supplier communication - sending structured PFAS questionnaires in version-controlled and traceable form to all relevant suppliers
  • Mapping compliance status in real time across the entire portfolio and linking it to PPWR declarations of conformity
  • Automatically identifying data gaps, so missing PFAS evidence becomes visible immediately

Assess your PFAS readiness

How well is your company prepared for the PFAS ban? Use the interactive quick check to identify areas where action is still needed:

Action recommendations for the coming weeks

12 August 2026 is approaching fast. Here are three concrete steps you should prioritise now:

  1. Start portfolio screening: Identify all food-contact packaging and assign risk classes. Begin with coated paper and board packaging.
  2. Engage your suppliers: Send standardised PFAS declaration templates to your packaging suppliers - with a clear reference to the PPWR thresholds and a concrete deadline.
  3. Build your compliance infrastructure: Assess whether your current data management (often Excel) can withstand a PPWR audit. If not, now is the time to invest in a digital solution that integrates PFAS tracking, DoC management and supplier communication.

Use the free PPWR checklist to document your current compliance status in a structured way. And join our free packaging webinars to stay up to date on the latest regulatory developments.