PFAS in packaging under the PPWR – what applies to producers from 12 August 2026

From 12 August 2026, Article 5 of the PPWR (EU 2025/40) sets EU-wide binding PFAS limits for food-contact packaging for the first time. PFAS have made headlines in other contexts too: milk samples have shown that soils in the north-east of the canton of St. Gallen are heavily contaminated with PFAS, bringing PFAS into the food chain. To minimise the entry of PFAS into the food chain through packaging, limits were written into the PPWR. In principle, packaging made of the commodity plastics polyethylene or PET is barely affected and falls into the lowest risk category.

You will find the full legal framework, all deadlines and the obligations for Swiss companies in our Market & regulation section.

The three PFAS limits under Article 5 PPWR

• 25 ppb for each individual non-polymeric PFAS measured
• 250 ppb for all non-polymeric PFAS measured together
• 50 ppm for all PFAS together, including polymeric PFAS

What are PFAS – and why are they a problem?

But what actually are PFAS? The Swiss Federal Office for the Environment (FOEN) explains: «Per- and polyfluoroalkyl substances (PFAS) are a group of several thousand synthetic industrial chemicals. They have been used on a large scale since the 1970s. Many PFAS are grease-, dirt- and water-repellent and extremely stable thermally and chemically. These properties are advantageous and useful in a wide range of products and processes, but PFAS are problematic in the environment and for health.»

PFAS are virtually non-degradable in the environment and are therefore also known as «forever chemicals». They pose a risk to health and to the environment. PFAS accumulate in the human body, in organisms, animals and sediments as well as in plants. For some PFAS – for example perfluorooctanesulfonic acid (PFOS) and perfluorooctanoic acid (PFOA) – harmful health effects are also known.

Because of their particular properties, PFAS are used in numerous applications and products: in firefighting foams (AFFF), non-stick coatings on kitchen utensils, grease- and water-repellent textiles, coated papers and boards, plastics, medical devices, ski waxes and many more.

Demonstrating compliance – a stepwise approach

Demonstrating compliance with the limits is challenging. There is as yet no harmonised methodology. The Commission therefore proposes a stepwise approach in its guidance:

• Test for total fluorine content. If this is below 50 mg/kg, the sample is considered compliant.
• If total fluorine exceeds that value, further analyses must separate fluorine into organic and inorganic fractions. If the organic fraction is then below 50 mg/kg, the sample is compliant.

The European Commission’s Directorate-General for Environment (DG ENV) has set up a PFAS task force to develop harmonised test protocols. Reportedly, reducing the 50 ppm threshold to 10 ppm is also under discussion.

Why does the PPWR address PFAS?

More and more cases of PFAS in the environment are coming to light. Because these substances barely degrade, they are called forever chemicals. In Switzerland the following cases drew attention:

• PFAS-contaminated meat in the canton of St. Gallen
• PFAS-contaminated drinking water following pollution from EuroAirport Basel
• PFAS in Lake Constance and the river Thur from firefighting water

A comprehensive study of PFAS in groundwater was carried out in Switzerland (the NAQUA study). A total of 550 monitoring sites were sampled. PFAS were detected in groundwater at just under half of them. Current limits were exceeded at only one site, however. Higher readings were mostly caused by PFAS-containing firefighting foams.

In November 2025 the German NGO BUND examined 46 drinking water samples and found PFAS in 42 of them. The limits due to be introduced in the EU from 2026 and 2028 were exceeded in several regions. PFAS are also found in food – for example in 69 percent of fish, 23 percent of milk and 14 percent of meat, according to BUND.

Back in January 2023, environmental authorities from five EU countries – Denmark, Sweden, Germany, the Netherlands and Norway – filed a dossier with the European Chemicals Agency (ECHA) to restrict PFAS. During the 2023 consultation more than 5600 responses were received. On 20 August 2025 ECHA published a revised restriction proposal. In the meantime both ECHA committees – the Risk Assessment Committee (RAC) and the Socio-Economic Analysis Committee (SEAC) – have completed their assessment. It remains unclear when and exactly how the restriction will be introduced.

Differentiating polymeric PFAS

PFAS are undesirable in the environment, that is not in question. The restriction should nevertheless take account of the fact that some PFAS are barely mobile in the environment: polymeric PFAS, or fluorinated plastics. The fluorine in these plastics is bound in long polymer chains and cannot simply escape. Fluorinated plastics are indispensable in medical technology, laboratory technology, environmental technology and electronics, and should be exempted from the restriction. What is needed instead is material-flow control, so that polymeric PFAS too are disposed of correctly at end of life.

What PFAS conformity means for plastic packaging

A 2026 study addresses how conformity with Article 5 of the PPWR can be achieved. The authors propose a risk matrix that classifies the risk of PFAS occurring in packaging from 1 (very low) to 4 (high). The classification is based on a literature review supplemented by analytical methods. Fibre-based packaging was identified as the most relevant packaging class for PFAS: because paper and board packaging is hydrophilic and lipophilic, it has to be coated so that liquid and fatty foods can be filled into it.

With plastics, PFAS coating is in some cases deliberate, in order to improve chemical and barrier properties. This is typically the case for chemical packaging, not for food packaging. In plastics, however, PFAS can also be present through processing aids or impurities in additives. The risk table for packaging shows that rigid PET and PE packaging carries barely any risk of containing PFAS:

Material	PFAS risk class
Plastics, mono
PET	1
PE-HD	1
PE-LD	1
PP	1
PS	1
rPET	1
rPE-HD, rPP, rPS	2
Paper
Pure paper	1
Recycled paper	4
Impregnated paper (grease-repellent)	4
Metal
Aluminium, uncoated	1
Aluminium, coated inside/outside	3
Steel, uncoated	1
Steel, coated inside/outside	3
Glass
Container glass	1

Our practice – how we test

The Semadeni Industry Group manufactures rigid plastic packaging at the group companies Biplast and Logo-Plastic. The packaging consists almost exclusively of rigid containers, mostly in PE-HD or PET. Our products therefore fall into the lowest PFAS risk category according to the study by Wack et al. (2026).

Even so, we wanted to validate the study results and had one PE-HD bottle and one PET bottle tested by the accredited testing laboratory TÜV Rheinland LGA Products GmbH. The test report of 6 May 2026 records that total fluorine content is below 50 mg/kg in both samples. The packaging is therefore considered compliant with the PPWR under the Commission’s guidance. The test method used was determination of halogens by oxidative pyrohydrolytic combustion followed by ion chromatography.

In addition, the laboratory carried out an individual assessment of PFAS substances (targeted screening). The PFAS substances were checked against current limits (25 ppb in the PPWR) and against future provisions expected to arise from the forthcoming PFAS restriction under the REACH Regulation. Both bottles were compliant here too.

How to demonstrate PFAS conformity

Responsibility for PFAS conformity lies with the producer – usually the filler. If you are a producer, the following approach is advisable for now, until harmonised test protocols under the PPWR are available:

1. Is this food packaging?
2. What materials does my packaging consist of – including labels, adhesives and printing inks?
3. How should the material-specific PFAS risk be classified?
4. Obtain a supplier declaration that no PFAS were deliberately used in the material and/or the manufacturing process.
5. Define, document and justify a testing strategy according to the risk classification. This essentially covers the frequency and the sampling approach for analysis.
6. Implement the testing strategy and have analytical tests carried out by accredited laboratories.
7. Compile documentation with all results – including the supplier declaration and other documents such as material data sheets and formulations.
8. Assess the packaging for conformity on the basis of the evidence in the documentation.
9. Incorporate this into the declaration of conformity (DoC) under the PPWR – see Market & regulation.

In summary

• Carry out a risk assessment of the packaging
• Define and implement a testing strategy
• Assess and document the results and include them in the declaration of conformity

Conclusion

From 12 August 2026, food packaging in the EU must meet strict PFAS limits. This applies to all packaging. The highest PFAS risk is carried by grease-repellent coated paper and board packaging. Rigid mono-material plastic packaging such as PE or PET carries a very low PFAS risk. Tests carried out for Semadeni at an accredited laboratory have demonstrated conformity with the PPWR.

More on the PPWR can be found in our Market & regulation section.