The EU's August PFAS packaging rule is already in force, and food contact packaging placed on the European Union market has to stay below three PFAS limits. The rule can be found in Article 5(5) of the EU Packaging and Packaging Waste Regulation, and it applies to packaging made anywhere in the world, including every carton, cup, wrapper, and liner that leaves a U.S. plant bound for a European customer.
That date has already passed. If you export food into the EU and you have not asked your packaging supplier for PFAS evidence yet, the container you ship next month is the one at risk.
What the EU's August PFAS Rule Actually Says
The rule is part of Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation (PPWR). It entered into force on 11 February 2025 and started to apply on 12 August 2026, according to the European Commission's packaging waste page.
Article 5(5) prohibits placing food contact packaging on the EU market if it contains PFAS at or above set concentration limits.
It states that food contact material and packaging is one of the most relevant sectors for PFAS tonnage, and that exposure to PFAS from food contact materials presents an unacceptable risk to human health.
PFAS stands for per- and polyfluoroalkyl substances, a family of thousands of synthetic chemicals valued for grease and water resistance.
The regulation uses a broad chemical definition rather than a named list, so a compound counts as PFAS if it contains at least one fully fluorinated methyl or methylene carbon atom.
The Three PFAS Limits That Apply to Food Contact Packaging
Packaging cannot be placed on the EU market if it hits or passes any of these thresholds. Note the wording, because at or above the number fails, which leaves you no margin to argue a borderline result:
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25 ppb (25 µg/kg)
Any single PFAS measured by targeted analysis, with polymeric PFAS excluded from quantification. Targeted analysis means the lab looks for named compounds it can identify and quantify individually, so one substance crossing this line fails the whole pack even if every other PFAS reads clean.
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250 ppb (250 µg/kg)
The sum of PFAS measured by targeted analysis, where relevant after degrading precursors, again excluding polymeric PFAS. Precursor degradation is the step that forces unstable fluorochemicals to break down into stable PFAS the lab can actually see, which is how a coating that looked compliant under direct testing can still fail here.
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50 ppm (50 mg/kg)
Total PFAS, this time including polymeric PFAS. Polymers such as PTFE and fluoropolymer dispersions are counted at this level, so a barrier film that passes the two ppb limits can still breach the regulation on total content.
Which Packaging the Rule Covers and Which It Leaves Out
The restriction applies to packaging intended to come into contact with food or already in contact with it. In practice, that captures more than the obvious items:
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Paper and paperboard with grease-resistant coatings or barriers.
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Cartons, clamshells, pizza boxes, and trays.
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Paper wraps and liners, sheets, and sandwich bags.
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Cup stock, fiber bowls, and lidding.
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Adhesives, inks, and coatings used in those components.
Transport and tertiary packaging with no intended food contact sits outside Article 5(5). Pallet wrap, edge protectors, and outer shipping cases are not caught, though they still fall under other parts of the PPWR.
Also, contamination counts, not just deliberate use. Recycled fibre can carry PFAS residues from earlier product lives, so "we never specified a fluorochemical" is an explanation rather than a defence. The limits are concentration-based.
Why U.S. Brands Are Not Automatically Compliant
Plenty of American food companies assume this is handled because the U.S. market moved first on grease-proofers. That assumption is half right and fully risky.
The FDA announced on 28 February 2024 that grease-proofing substances containing PFAS are no longer sold by manufacturers for food contact use in the U.S. market. The agency described that voluntary phase-out as removing the primary source of dietary exposure to PFAS from authorised food contact uses.
Removing the primary source still leaves three gaps:
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Scope
The announcement covered grease-proofing agents on paper and paperboard. PFAS used for other functions, and PFAS in other materials, sat outside it entirely.
Fluoropolymer films, coated board that was never classed as a grease-proofer, and imported stock all fall into that space, and so does any packaging converted outside the United States and shipped in.
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Evidence
The phase-out commitments did not create a documentation trail an EU market surveillance authority will accept.
Those were agreements between the FDA and chemical manufacturers rather than records tied to your SKUs, and the EU expects evidence attached to the specific packaging you placed on the market, with the material, the production site, and the date range named.
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Residual contamination
Nothing in the phase-out addresses PFAS arriving through recycled content or shared production lines.
Recovered fibre can carry residues from the packaging it used to be, and a coating line that once ran fluorochemical formulations can leave traces in later runs. Both routes produce measurable PFAS in packaging nobody intentionally treated.
How the EU Rule Compares With U.S. State PFAS Laws
Eleven states have adopted laws banning or restricting PFAS in food packaging, including California, New York, Minnesota, Washington, Colorado, Connecticut, Maryland, Maine, Vermont, Rhode Island, and Hawaii. Most target intentionally added PFAS. California adds a numerical trigger.
Four differences matter most when you compare the two regimes:
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What triggers it
Most state laws turn on intentionally added PFAS, while the EU rule turns on measured concentration and ignores intent entirely.
That single difference changes your whole defence. Under an intent-based law, a supplier statement saying nothing was added can carry you a long way. Under Article 5(5), the lab result decides, and a clean intent record counts for nothing if the number comes back over.
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The numbers
California works to 100 ppm total organic fluorine, where the EU applies 25 ppb, 250 ppb, and 50 ppm alongside a 50 mg/kg fluorine screen.
The EU screening value is half the California trigger, and the targeted limits are four orders of magnitude tighter. Packaging that cleared a California review can still sit well above the EU thresholds, because nobody was ever measuring at that resolution.
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The proof
states often accept a supplier certificate of compliance, whereas the EU expects Annex VII technical documentation behind an EU declaration of conformity. A certificate is a statement.
Technical documentation is a file holding test results, material specifications, and supplier declarations that an inspector can work through, and assembling one takes considerably longer than requesting a letter.
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The materials
State rules are frequently limited to plant fibre packaging, while Article 5(5) reaches every food contact packaging material.
Plastics, films, laminates, metal with internal coatings, and the adhesives and inks on all of them fall inside the EU restriction. If your state compliance work only ever covered paper and board, a substantial part of your range has never been assessed.
A California-compliant certificate does not carry you into Europe. California's 100 ppm organic fluorine figure is twice the EU's screening value, and the EU's targeted limits are in parts per billion. Groundwork you have already done still helps, and our breakdown of Maine's May 2026 PFAS deadline shows how the U.S. picture has been tightening alongside it.
How to Check Your Packaging Before Your Next EU Shipment
Work through this in order, because it moves from cheapest to most expensive.
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Build a component list
Break every EU-bound SKU into its parts, including the substrate, coating, adhesive, ink, window film, and liner.
A compliant board with a non-compliant coating still fails, so the list has to go deeper than the item name on your purchase order. Group components that share a material and a supplier, because testing is priced per sample and one result can often cover several SKUs.
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Request a written PFAS statement
Ask each supplier for a declaration covering no intentionally added PFAS, plus any fluorine or PFAS test data they already hold, referenced to Article 5(5) of Regulation (EU) 2025/40.
Insist that it names the material, the production site, and the date range it applies to. A generic company-wide letter will not survive an inspection, and asking for the specific version now saves a second round of emails later.
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Screen the gaps for total fluorine
Send samples of any component with no credible data behind it. A result below 50 mg/kg lets you stop there and record that outcome, which resolves most components quickly. Build the testing into one batch rather than drip-feeding samples, since labs price and schedule that way.
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Escalate only where needed
For components above the screen, establish whether the fluorine is organic or inorganic, then run targeted analysis against the 25 ppb and 250 ppb limits. Fluorine from mineral fillers or pigments is inorganic and resolves the question without further work. Only genuinely suspect components should reach the expensive stage.
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Assemble the technical documentation
Pull results, declarations, and material specifications into the Annex VII file supporting your EU declaration of conformity. Keep it per packaging unit rather than per shipment, and store it where someone other than you can find it, because the request will not always arrive while you are at your desk.
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Lock it into procurement
Add PFAS evidence to supplier onboarding and to your written purchase specifications so the next material change does not quietly reopen the question. A substrate swap, a new coating, or a mid-contract mill change can all reset your compliance position without anyone flagging it.
One thing this process does not cover. PFAS compliance sits on top of the EU's food contact framework rather than replacing it, so packaging intended to touch food still has to meet Regulation (EC) No 1935/2004.
The good news is that the declarations of compliance you already hold under that framework usually slot straight into your PPWR file, which saves duplicating work you have done.
What to Look for When Sourcing EU-Ready Food Packaging
PFAS evidence now belongs in the sourcing conversation alongside cost, lead time, and performance. A few things are worth pressing on:
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Barrier technology
Modern grease resistance comes from engineered fibre, dispersion coatings, and laminates rather than fluorochemistry.
Ask what the barrier actually is, in plain terms, and be wary of an answer that stops at "proprietary". Each approach behaves differently, so a dispersion-coated board and a laminated one can perform the same on day one and diverge once your product sits in them for an hour.
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Performance in service
A wrapper that holds grease at ambient and fails under a heat lamp creates a different problem, and the switch away from fluorochemical treatments is exactly when that shows up.
Test with your own product, at your own hold times and temperatures, rather than relying on a generic grease resistance rating. Our guide to choosing a pizza box for ventilation, grease resistance, and stackability covers those trade-offs.
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Supply chain visibility
A supplier that manufactures rather than brokers can trace a coating back to a specific line and run, which is the level of detail an Annex VII file needs.
Ask who owns the converting plant, whether the coating is applied in-house, and how quickly they can produce mill-level data when a customer asks. A supplier who has to chase three parties for an answer will be slow every time.
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Wider PPWR readiness
PFAS is the first deadline rather than the last one. Recyclability grades, recycled content targets, and labelling requirements phase in through 2030, and producer responsibility fees already reward better design, as our explainer on eco-modulated EPR fees sets out.
Choosing a format now that only solves the PFAS question means revisiting the same SKUs in two years, so it is worth asking how a supplier is preparing for the rest of the regulation.
Talk to SupplyCaddy About Your EU-Bound Packaging
SupplyCaddy is a global manufacturer of foodservice packaging and disposables, headquartered in Miami with manufacturing facilities in North America, South America, and Europe. That European footprint shortens the distance between your specification and the line that runs it.
We have delivered more than a billion products for brands including Burger King, sweetgreen, Krispy Krunchy Chicken, Fuku, Guthrie’s Popeyes, Cinnabon, Hardee's, Tijuana Flats, H&H Bagels, Margaritaville, and more! Our products reach operators through distributors such as Sysco, US Foods, Gordon Food Service, Performance Food Group, and Imperial Dade.
Custom branding comes at no extra cost. No tooling fees, no plating fees, no ink fees, so switching a SKU for an EU-bound line does not force a choice between compliance and a branded pack. We also create plotter samples, which lets you test a prototype before a full run lands.
Reviewing your export packaging? Get in touch with our team with your SKU list, or browse our food containers and paper wraps to see what fits your format. Contact us at hello@supplycaddy.com.
Frequently Asked Questions
When did the EU PFAS packaging rule take effect?
It took effect on 12 August 2026. That is the date Regulation (EU) 2025/40 started to apply, and Article 5(5) has restricted PFAS in food contact packaging placed on the EU market from that day forward.
Is the EU PFAS rule a total ban?
No, it sets concentration limits rather than an outright prohibition. Food contact packaging cannot be placed on the EU market at or above 25 ppb for any individual PFAS, 250 ppb for the sum of PFAS by targeted analysis, or 50 ppm for total PFAS including polymeric PFAS.
Does the rule apply to packaging manufactured in the United States?
Yes. The restriction attaches to packaging placed on the EU market rather than to where it was made, so U.S.-manufactured cartons, cups, and wrappers face the same limits as packaging produced inside the bloc.
Can I sell through existing stock that contains PFAS?
Packaging already placed on the EU market before 12 August 2026 is not caught, but there is no general sell-through period for non-compliant packaging supplied after that date. The Commission confirmed this in its PPWR FAQ, so production date alone does not exempt a shipment.
What testing do I need to prove compliance?
Start with total fluorine screening, since a result below 50 mg/kg allows a component to be treated as compliant. Where fluorine exceeds that level, establish whether it is organic or inorganic, then run targeted PFAS analysis, with direct TOP analysis recommended for the 25 ppb and 250 ppb thresholds.
Does a California PFAS compliance certificate work in the EU?
No. California triggers at intentionally added PFAS or 100 ppm total organic fluorine, while the EU applies parts-per-billion limits regardless of intent and expects Annex VII technical documentation plus an EU declaration of conformity.
Who is responsible if non-compliant packaging reaches the EU?
The importer placing packaging on the EU market must ensure compliance and keep the manufacturer's documentation available for inspection.
An importer or distributor selling under its own name or trademark takes on the manufacturer's obligations, which is why branded packaging usually puts responsibility back on the food brand.