From 12 August 2026, PPWR Article 5 prohibits PFAS (per- and polyfluoroalkyl substances) in packaging that directly contacts food. If your brand sells food products — or any product where packaging touches what people consume — this ban deserves your attention now.
PFAS is a family of thousands of synthetic fluorinated compounds. They're extraordinarily durable — resistant to heat, water, grease, and oil. Those properties made them useful as coatings for food-contact packaging where grease resistance was needed.
Common uses in food packaging:
PFAS problems: they're persistent (they don't break down in the environment or in the body), they bioaccumulate (they build up in living organisms), and they're linked to a range of health effects including thyroid disruption, immune system effects, and certain cancers at high exposures.
PPWR Article 5 bans packaging that contains PFAS above specified concentration thresholds in food-contact applications. The prohibition covers:
The ban is on PFAS in food-contact packaging specifically — not on PFAS in all packaging. Packaging that doesn't contact food is not covered by this particular prohibition (though PFAS may be restricted by other EU chemical regulations such as REACH).
The prohibition is absolute from 12 August 2026 — there are no derogations, thresholds below which it's acceptable, or grace periods for "legacy" packaging stocks already in warehouses. Any packaging you use after that date must be PFAS-free.
Definitely in scope:
Probably not in scope:
Check even if you're uncertain: The test is whether packaging comes into direct contact with food or beverage product. If your packaging touches what someone eats or drinks, assume it may be affected and verify.
List every packaging element that directly contacts food or beverages:
Contact your packaging suppliers and request a formal declaration confirming PFAS content. Specifically ask for:
Reputable packaging suppliers should already have this documentation for EU-sold products, since PFAS restrictions have been building in EU food contact material law for several years before PPWR. If a supplier cannot or will not provide a PFAS declaration, treat that as a red flag.
If a supplier declaration is unavailable or if you're using legacy stock from before PFAS restrictions became prominent, you can commission analytical testing. The standard test for total fluorine content in packaging is:
Testing costs typically £200–£800 per sample. Not necessary if you have clear supplier declarations.
The good news: PFAS-free alternatives exist for every common food packaging application. The industry has been developing these for years in anticipation of EU restrictions.
| Application | PFAS-based (now banned) | PFAS-free alternatives |
|-------------|------------------------|----------------------|
| Grease-resistant burger/sandwich wraps | PFAS-coated paper | Clay-coated paper; wax coating; PLA coating; silicon-based coatings |
| Grease-resistant bakery bags | PFAS-coated kraft paper | Silicone-treated paper; PE-laminated kraft (check recyclability); wax-coated paper |
| Microwave containers | PFAS-coated board | PFAS-free mineral-coated board; moulded fibre (pulp); PLA-coated board |
| Pizza boxes | PFAS-coated corrugated | Enhanced mineral-coated corrugated; clay-coated; wax-coated |
| Pet food flexible pouches | PFAS-coated multi-layer film | PVOH (polyvinyl alcohol) barrier layers; evaporated SiOx/AlOx barrier; nanocomposite barrier |
| Coffee/tea bags | Some PFAS-coated formats | Uncoated natural fibre; PLA-sealed biodegradable formats |
Note on recyclability: Some PFAS-free alternatives (PE laminates, wax coatings) may introduce their own recyclability challenges. When switching away from PFAS, check that your alternative is compatible with your EPR eco-modulation position — you don't want to solve the PFAS problem while creating a non-recyclability surcharge.
The ban is absolute from 12 August 2026. "Legacy stock" — packaging manufactured before that date — still cannot be used after that date if it contains PFAS. The ban covers the use of packaging containing PFAS in food contact applications, not just its manufacture or import.
Practical lead times for switching:
Total: 18–36 weeks from decision to deployed alternative. For brands still using PFAS-coated packaging and not yet in a switching process, the window to comply by August 2026 is narrow.
Once you've switched to PFAS-free packaging:
PPWR Article 5 targets food-contact packaging specifically. But PFAS are increasingly restricted across EU chemical regulation more broadly:
For non-food packaging, the PPWR ban doesn't apply — but check whether any PFAS-containing components are restricted under other regulations, particularly if they're in contact with skin (cosmetics packaging, personal care products).
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For the full PPWR compliance picture, see PPWR explained for e-commerce brands: what changes in August 2026.