The pressure to comply with PFAS regulations is rapidly increasing
PFAS have been high on the European agenda for several years now. While attention used to be focused primarily on drinking water, soil contamination, and industrial emissions, the focus is increasingly shifting to packaging materials that come into contact with food.
With the introduction of the Packaging and Packaging Waste Regulation (PPWR), not only are the regulations surrounding PFAS changing, but so is the way companies must demonstrate packaging compliance. For QA and compliance professionals, this means that supplier declarations alone are no longer always sufficient. The question being asked more and more often is: how can you objectively demonstrate that a packaging product actually complies?
What is changing under the PPWR?
The Packaging and Packaging Waste Regulation (PPWR) will largely take effect on August 12, 2026. For food contact packaging, the regulation introduces specific limit values for PFAS.
One of the most significant changes for the food industry is the restriction on PFAS in food contact packaging. Starting August 12, 2026, packaging intended to come into direct contact with food may only be placed on the market if it complies with the established limit values for PFAS. The limits are 25 ppb for individual PFAS, 250 ppb for the sum of PFAS, and 50 ppm for total organic fluorine (TOF), including polymeric PFAS. For packaging with a higher total fluorine content, it must also be demonstrated that the fluorine present does not originate from PFAS. These requirements make analytical verification increasingly important within the compliance dossier for food contact materials.
The introduction of a TOF limit is particularly relevant. Whereas traditional PFAS analyses focus on specific compounds such as PFOS or PFOA, TOF examines the total amount of organically bound fluorine in a material. This allows for the detection of fluorine-containing polymers and other PFAS-related compounds that are not always detectable in standard PFAS screenings. For companies seeking to demonstrate compliance of packaging materials, a combination of supplier documentation and targeted analytical verification will therefore become increasingly necessary.
This shifts the focus from general compliance statements to demonstrable compliance.
Why is this a challenge?
Many companies today rely on documentation from packaging suppliers. While this remains an important foundation, in practice packaging supply chains are often complex. Materials consist of multiple layers, coatings, inks, adhesives, and additives that may come from different suppliers.
Furthermore, packaging is regularly modified without end users always having full insight into the composition of the materials used. This raises an important question: how certain are you that the documentation provided still matches the material that is actually being delivered?
This is precisely why there is a growing focus on analytical verification as part of a robust compliance program.
Not all PFAS are detectable in standard analyses
When companies consider PFAS testing, they often focus on specific compounds such as PFOS or PFOA. These substances can be analyzed using targeted techniques such as LC-MS/MS.
However, the new PPWR looks beyond just individual PFAS components. Polymeric PFAS also fall within the scope of the regulation. This makes the assessment more complex, because not all PFAS can be detected using conventional screening methods.
Consequently, a package may comply with the limits for individual PFAS, yet still contain fluorinated polymers that are relevant to the conformity assessment.
The Role of TOF Analysis
For this reason, Total Organic Fluorine (TOF) analysis is receiving increasing attention.
TOF determines the total amount of organically bound fluorine in a material. This provides a broader picture of the potential presence of PFAS than when only individual compounds are examined. According to the PPWR, this approach plays an important role in demonstrating compliance for packaging that may contain fluorinated compounds.
In practice, total fluorine (TF) is first determined. Next, inorganic fluorine (TIF) is quantified. Subtracting one value from the other yields the organic fluorine content (TOF), which can serve as an indicator of the presence of PFAS.
When should you perform PFAS analyses?
Not all packaging poses the same risk. Materials for which grease-, moisture-, or dirt-repellent properties are crucial deserve special attention. This includes, for example, paper and cardboard packaging for fast food, baked goods, take-out meals, and food containers, as well as other applications where a reliable barrier function is essential.
Analytical verification can be particularly valuable when there is a change in supplier, the introduction of new packaging materials, or situations where existing documentation is incomplete or insufficiently clear. PFAS analysis can also provide relevant insights when customers request additional supporting documentation, when organizations are preparing for audits or inspections, or when old packaging specifications are reevaluated in light of the PPWR.
Supplier declaration or analytical evidence?
The answer is not: either documentation or analysis.
An effective compliance system combines both. Supplier documentation remains essential for understanding the materials used and the legal basis. Analyses then provide independent verification of this information.
It is precisely this combination that helps organizations better manage risks in the packaging chain and be better prepared for audits, customer inquiries, and inspections.
From Compliance to Demonstrable Conformity
The introduction of the PPWR marks a significant shift in packaging compliance. Whereas companies could previously often rely on supplier declarations, there is now a growing need for objective and analytically substantiated evidence.
For QA professionals, now is the time to critically evaluate existing packaging portfolios. Which materials pose an increased risk? What documentation is available? And where can additional analytical verification contribute to a stronger compliance dossier?
How can Normec Foodcare help?
Our experts assist food companies in assessing food contact materials and developing a risk-based approach to PFAS compliance. Through targeted PFAS analyses, screenings of individual PFAS components, and TOF analysis, we help organizations verify supplier information and better substantiate the compliance of packaging materials.
Would you like to know if your packaging is ready for the PPWR? Our specialists would be happy to work with you to determine which analyses are most relevant to your packaging portfolio.