PPWR for Food-Contact Packaging: Understanding the New PFAS Restrictions

Food-contact packaging now faces an additional compliance layer under the PPWR.

From 12 August 2026, Article 5 prohibits food-contact packaging from being placed on the EU market where PFAS reaches or exceeds the regulation's specified concentration limits.

For buyers of plastic buckets, bottles, jars and dispensing components used with food, this means PFAS should now be considered alongside traditional food-contact requirements.

PPWR Does Not Replace Food-Contact Legislation

A common mistake is to treat PPWR as a replacement for existing food-contact rules.

It is not.

A plastic packaging project may simultaneously require consideration of:

Regulation (EC) No 1935/2004

Regulation (EU) No 10/2011

REACH

Regulation (EU) 2025/40 PPWR

Each covers a different regulatory purpose.

For example, migration testing helps evaluate food-contact suitability, while PPWR Article 5 introduces separate packaging substance requirements.

What Buyers Should Request

For food-contact plastic packaging, request documentation that matches:

Material

Product family

Capacity/model

Intended food-contact use

Testing conditions

Regulatory scope

A PP bucket report should not automatically be assumed to cover an unrelated HDPE bottle.

Likewise, a resin change or additive change may affect whether previous evidence remains representative.

PFAS Evidence Should Be Product-Specific

A statement such as:

“Our material is PFAS free”

is weaker than a clearly identified third-party test report.

Buyers should look for:

• sample identification;

• material description;

• applicable regulation;

• test method;

• report date;

• conclusion.

Complementary Compliance Evidence

For selected UMETASS product families, the current compliance portfolio includes separate evidence for:

EU Food Contact

REACH SVHC

and, for selected PP and HDPE packaging:

PPWR testing.

This allows documentation to be matched more closely to the actual packaging project.

Conclusion

For European food packaging, PPWR should now be considered part of a broader compliance package rather than a standalone badge.

A strong supplier should be able to explain not only:

whether a test exists,

but:

which product, material and regulatory requirement the report actually supports.