PPWR introduces limits on PFAS and hazardous substances in packaging

The European Union has long been working to improve the safety of packaging, particularly that intended to come into contact with food. Following the ban on bisphenol A (BPA), the time has come for further bans and restrictions – this time concerning PFAS and heavy metals. The PPWR Regulation sets permissible limits for specific substances and does not rule out the possibility that these strict requirements may be tightened even further in the coming years.

When did the new limits for PFAS and heavy metals come into force?

The ban on placing on the market packaging that exceeds the limits for PFAS and heavy metals specified in the PPWR applies from 12 August 2026. The PPWR Regulation does not provide for a transitional period to allow existing stocks of packaging containing PFAS or heavy metals to be used up – if they were not placed on the market before 12 August 2026, they will no longer be allowed to enter the market.

NOTE: the point at which something is considered to be „placed on the market” varies depending on the type of packaging. According to the European Commission’s interpretation, retail and bulk packaging intended to come into contact with food is placed on the market once it has been filled, provided that the final stages of processing (e.g. sealing processes) may affect the packaging’s compliance with the regulations. Transport and service packaging is placed on the market when empty.

Packaging placed on the market before 12 August 2026 may remain on the market and does not need to be withdrawn.

Restrictions on PFAS in food packaging – PPWR requirements

The following has been in force since 12 August 2026 prohibition on placing on the market packaging intended to come into contact with food, which contains high concentrations of per- and polyfluoroalkyl substances (PFAS). It covers all contact packaging, regardless of the material from which it is made, in which the PFAS content is:

• 25 ppb (μg/kg) or more for individual PFAS substances,
• 250 ppb (μg/kg) or more for the total of all PFAS substances,
• 50 ppm (mg/kg) or more of PFAS (including polymeric PFAS).

If the total amount of fluorine exceeds the maximum concentration of 50 mg/kg, the manufacturer, importer or downstream user must prepare detailed technical documentation distinguishing PFAS from other compounds.

New maximum limits for hazardous substances in packaging

In accordance with the PPWR Regulation, All packaging should be designed and manufactured in such a way as to limit the content of certain heavy metals and other potentially hazardous substances. From 12 August 2026, only packaging in which the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium does not exceed 100 mg/kg. This requirement applies to both complete packaging units and all their constituent parts. In future, the permissible limits for heavy metals and potentially hazardous substances may be lowered – the new regulations authorise the European Commission to adopt delegated acts to set lower limits, taking into account the current state of the art.

The preamble to the PPWR Regulation states that the imposition of limits on hazardous substances is intended not only to protect public health and the environment, but also to support the transition to a circular economy. The EU wishes to avoid a situation in which recycled packaging materials containing excessive concentrations of heavy metals are repeatedly used in the production of further packaging and reintroduced onto the market.

The responsibility for ensuring that the packaging complies with the limits on hazardous substances set out in Article 5 of the PPWR Regulation lies with first and foremost, the manufacturer packaging. The manufacturer is obliged to carry out a conformity assessment procedure based on the information and documentation provided by the suppliers of raw materials and packaging materials. If the packaging successfully passes this procedure, the manufacturer draws up an EU declaration of conformity for it, confirming compliance with all currently applicable PPWR requirements.

Find out who is considered a manufacturer under the provisions of the PPWR >>

Furthermore, the following is also responsible for ensuring that packaging placed on the EU market complies with the relevant requirements: an importer who must ensure that the manufacturer has fulfilled its obligations relating to the conduct of the conformity assessment procedure, the preparation of technical documentation and the EU declaration of conformity.

To a certain extent, distributors and fulfilment service providers are also responsible for ensuring that packaging complies with the requirements regarding limits on potentially hazardous substances. They are obliged to store, handle, pack, address and dispatch packaging in a manner that does not adversely affect the content of these substances.

What are PFAS?

PFAS, i.e. per- and polyfluoroalkyl substances that a large group of synthetic compounds chemicals containing carbon–fluorine bonds, which are amongst the strongest bonds found in organic chemistry. It is precisely because of these bonds that PFAS They are exceptionally resistant to high temperatures, fats, water and most chemicals. Owing to their very slow rate of degradation in the environment and their ability to accumulate in soil, water, animals and humans, are sometimes referred to as „eternal chemicals”.

Several thousand different substances classified as PFAS have now been identified. The best-known compounds in this group include, amongst others, PFOA (perfluorooctanoic acid), PFOS (perfluorooctane sulfonate) and PFHxS (perfluorohexanesulfonic acid).

Technical note on Article 5(5) of the PPWR Regulation: PFAS means any substance that contains at least one fully fluorinated carbon atom in a methyl group (CF3-) or methylene group (-CF2-) (without any attached H/Cl/Br/I atoms), with the exception of substances containing exclusively the following structural units: CF3-X or X-CF2-X’, where X = -OR or -NRR’ and X’ = methyl (-CH₃), methylene (-CH₂-), an aromatic group, a carbonyl group (-C(O)-), -OR’’, -SR’’ or –NR’’R’’’, and where R/R’/R’’/R’’’ is hydrogen (-H), methyl (-CH₃), methylene (-CH₂), an aromatic group or a carbonyl group (-C(O)-).