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Europe Limits PFAS Products in Packaging, New Regulations to Take Effect in 2026, Are You Ready?

Bioplastics Research Institute 2025-12-29 11:21:51

PFAS are extremely difficult to degrade in the natural environment and can accumulate in the human body and ecosystems. Numerous studies have confirmed their association with endocrine disruption, liver and kidney damage, immune suppression, and even an increased risk of cancer.

According to a report from the Bioplastics Research Institute, a survey conducted in early 2025 showed that over 90% of pulp molded tableware products in China have excessively high total fluorine content. If compared to relevant EU standards, the levels far exceed the limit, with the highest reaching 16.6 times the limit value.
On January 22, 2025, the European Union officially published the Packaging and Packaging Waste Regulation, Regulation No. (EU) 2025/40, which will take effect on February 11, 2025. According to the regulation, it will be fully implemented on August 12, 2026, and will simultaneously repeal the old directive 94/62/EC that has been in use for nearly 30 years. One of the most concerning provisions is regarding per- and polyfluoroalkyl substances (PFAS).

PFAS are a class of fluorinated organic compounds known for their superior waterproof, oil-resistant, and high-temperature-resistant properties. They have long been widely used in food contact materials (such as greaseproof paper and fast-food box liners), cosmetics (waterproof mascara and foundation), textiles (coatings for outdoor clothing), non-stick cookware, and firefighting foams. However, PFAS are extremely difficult to degrade in the natural environment and can persistently accumulate in the human body and ecosystems. Multiple studies have confirmed their association with endocrine disruption, liver and kidney damage, immune suppression, and even increased cancer risk. Therefore, the European Union has classified them as "substances of concern" for priority regulation.

Article 5 of the PPWR stipulates that, starting from August 12, 2026, all packaging materials intended for food contact must adhere to the following limits: the content of each PFAS substance must not exceed 25 ppb (parts per billion); the total content of all PFAS must not exceed 250 ppb; the total PFAS content calculated as fluorine must not exceed 50 ppm (parts per million). Additionally, if the total fluorine content in the packaging exceeds 50 ppm, manufacturers or importers must provide downstream customers with documentation verifying the source of the fluorine content, whether PFAS or non-PFAS, ensuring traceability and verifiability.

 

The European Union is not an isolated case; PFAS restrictions are becoming a global trend. The U.S. Food and Drug Administration (FDA) announced in April 2024 that food contact oil-resistant materials containing PFAS will no longer be sold in the United States, and states like Minnesota and Colorado have already banned the use of PFAS in food packaging. Japan will prohibit the use of 138 types of perfluorinated compounds starting January 10, 2025. France will ban the sale of cosmetics and textiles containing PFAS from 2026 onward. China has implemented bans or strict restrictions on typical perfluorinated compounds such as PFOS, PFOA, and PFHxS, but has not completely banned all PFAS.

 

Chinese companies face various risks. If packaging is found to exceed PFAS limits, products may be refused entry, recalled, or destroyed; many companies have yet to identify whether their packaging contains PFAS (such as oil-resistant coatings, adhesives, and inks). Environmental compliance has become a core procurement standard for international buyers such as IKEA, Nestlé, and LVMH.

 

It is especially noteworthy that PFAS may be present in seemingly "ordinary" packaging: the oil-resistant coating on the inner layer of kraft paper bags; coffee filters, tea bags; frozen food paper boxes; fast food paper trays, baking paper, etc., all of which fall under the "food contact packaging" clearly covered by PPWR.

 

To proactively address the issue, companies should require all packaging suppliers to provide PFAS-free declarations and conduct third-party testing on high-risk materials such as paper products, composite films, and coatings. They should adopt fluorine-free oil-resistant technologies like starch-based, chitosan, and PLA coatings. Additionally, they should select compostable packaging certified by OK Compost, TÜV Austria, and collaborate with organizations such as SGS, TÜV, and CTI to conduct compliance assessments.

 

The implementation of PPWR is not only an upgrade of environmental regulations but also a signal for the reconstruction of the global consumer goods value chain. Whoever can first achieve a green packaging transformation of "PFAS-free, recyclable, and reduced" will win the access pass to the high-end markets of the EU and even globally.

 

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