The topic of PPWR and PFAS is often reduced to a chemistry question: which substances are present, and at what concentration? For a manufacturer, the real question lies elsewhere. Proving the absence of PFAS in packaging means obtaining an up-to-date composition declaration for every product reference and from every supplier, then keeping it current over time. It is a supplier data collection and traceability problem, not a laboratory problem.
By Gautier VeyssetIndustry specialist writer at Tracklab · LinkedInUpdated 13 Oct 202614 min read7 sources citedThis guide is intended for Quality, Regulatory, R&D and Purchasing teams in manufacturing and the food industry. It explains what the PPWR Regulation requires on substances of concern, which packaging is most exposed and, above all, how to structure supplier evidence - the most fragile part of a PFAS file.
PFAS refers to a very large family of per- and polyfluoroalkyl chemical substances, whose common feature is a particularly stable carbon-fluorine bond. This stability has earned them the nickname “forever chemicals”: they degrade very slowly in the environment and can accumulate in food chains. Forever chemicals in packaging therefore do not concern a single substance, but an entire family.
Their properties - resistance to water, grease and heat - have made them useful in several packaging functions:
In other words, PFAS are not always in the main material: they can be found in a component - a treatment, an adhesive, an ink. This is precisely what makes the evidence hard to collect.
“Paper” or “board” packaging is neither exempt nor automatically concerned. Everything depends on the treatment applied and on the components. Packaging composition must therefore be documented component by component.
The PPWR Regulation (Regulation (EU) 2025/40) addresses substances of concern from two complementary angles. Monitoring substances of concern in packaging is therefore not limited to a one-off ban: it combines a general principle and a targeted restriction.
The regulation requires the presence of substances of concern in packaging to be minimised, taking into account their impact on health and the environment. It does not set out a fixed list of banned substances: it lays down a minimisation principle and refers to the relevant texts and implementing acts for the detail.
For food contact PFAS, the regulation sets limits applicable to packaging intended to come into contact with food. These limits are based on several measurements - an individual PFAS, the sum of several PFAS, and total fluorine - and come with a justification requirement when the fluorine content exceeds a certain level.
“From 12 August 2026, food-contact packaging shall not be placed on the market if it contains per- and polyfluorinated alkyl substances (PFAS) in a concentration equal to or above the following limit values […]: (a) 25 ppb for any PFAS as measured with targeted PFAS analysis […]; (b) 250 ppb for the sum of PFAS […]; and (c) 50 ppm for PFASs (including polymeric PFAS) […].”Regulation (EU) 2025/40, Article 5, paragraph 5 · EUR-Lex, official text
The precise thresholds, their units and their date of application must be checked in the official text and the implementing acts, according to the use category of your product. A robust file does not quote these values from memory: it relies on the version of the regulation in force.
The PPWR does not ask you to do chemistry: it asks you to be able to demonstrate that the composition of your packaging complies with the applicable framework. This demonstration relies on data that you do not produce yourself.
To place this requirement within the overall framework, see the guide PPWR Regulation: complete guide to packaging compliance.
The PPWR sets a principle of reducing substances of concern and a specific restriction for PFAS in food contact. The difficulty is not the rule, but the documentary evidence that supports it, reference by reference.
Source: Regulation (EU) 2025/40, Article 5, paragraph 5. Check applicability to your use category.
Not all packaging carries the same risk. The table below helps you prioritise: it cross-references the type of packaging, the level of risk and the data to obtain first.
| Packaging type | Risk level | Data to obtain |
|---|---|---|
| Food packaging with a grease or water barrier | High | Composition declaration + PFAS status of the treatment |
| Treated paper and board (grease-resistant, coating) | High | Nature of the treatment, absence of PFAS, supplier of the treatment product |
| Multilayer and composite packaging | High | Layer-by-layer composition, adhesives, inks, barriers |
| Tableware, trays, sealed trays | Medium to high | Food contact status + composition declaration |
| Packaging in direct contact with food | High | Combined food contact and PFAS compliance |
| Secondary/tertiary packaging with no contact or treatment | Low to medium | Material composition, absence of fluorinated treatment |
Two prioritisation logics overlap:
Starting with food packaging that has a barrier avoids spreading the effort across an entire portfolio.
A “PFAS-free” claim reassures; it proves nothing. Four flaws keep recurring in files.
A commercial claim with no product reference, no method and no identification of the entity making it is not evidence that can be used in an audit.
A standard document saying “our packaging does not contain PFAS”, sent with no reference name or scope, says nothing about the packaging you actually place on the market.
A declaration must be linked to a specific reference, a use and a date. Without this link, it cannot be relied on against a given requirement.
This is the most critical point: a declaration that was valid last year may be wrong today if the supplier has changed its raw material or its treatment. The evidence becomes obsolete without anyone knowing.
PFAS evidence is only valuable if you know who issued it, for which reference, on what date and which version supersedes it. Without these four elements, “PFAS-free” remains a statement of intent.
What you need to ask for is the same whatever the supplier. The table below links each data point to its proof format, to who holds it and to how often it is updated.
| Data | Accepted proof format | Who holds it | Update frequency |
|---|---|---|---|
| Composition declaration (materials and components) | Signed, dated declaration with product reference | Packaging manufacturer / material supplier | For each new reference or change in specification |
| PFAS status of the product and its treatments | Dedicated declaration + reference to the applicable framework | Material supplier / manufacturer | For each change in formulation |
| Fluorine / PFAS analysis reports | Dated laboratory report (sample + method) | Laboratory / supplier | Depending on risk, at a set interval or on request |
| Food contact compliance | Declaration of compliance (material concerned) | Packaging manufacturer / supplier | For each change affecting migration |
| Identification of components (inks, adhesives, varnishes) | Technical data sheet per component | Component supplier | For each change of component |
| Contact details and version of the source | Stated on each document (issuer, date, version) | All | At each issue |
To frame the collection of the evidence supporting the PPWR declaration of conformity, supplier regulatory document management sets out the rules.
Six data points are enough to structure a PFAS file: composition, PFAS status, analyses, food contact compliance, components and source traceability. What differs from one supplier to another is the ability to provide them in a usable format.
This is the blind spot of most PFAS files: a supplier changes a raw material, a treatment or an additive without telling you. The declaration you hold remains filed, dated, apparently valid - and yet wrong. The evidence becomes obsolete without any warning.
Without these mechanisms, you only discover the change during an inspection, a customer complaint or a quality incident - too late.
The PFAS risk is not only failing to know that a substance is present: it is believing a piece of evidence is valid when it no longer is. Tracking versions and deadlines is as important as the first collection.
The PFAS topic cuts across several regulations. They do not replace one another: they overlap on the same packaging. Confusing them leads to producing the wrong evidence for the wrong authority.
| Framework | Subject | Authority / reference | Expected evidence |
|---|---|---|---|
| PPWR | Packaging and packaging waste: substances of concern, PFAS in food contact | Regulation (EU) 2025/40 | Declaration of conformity, composition, PFAS status |
| Food contact | Safety of materials in contact with food | Regulation (EC) 1935/2004 and specific measures (e.g. 10/2011 for plastics) | Declaration of compliance, migration documentation |
| REACH | Chemical substances: manufacture, placing on the market, use | Regulation (EC) 1907/2006, ECHA restrictions | Safety data sheets, compliance with restrictions |
| National regulations | Measures specific to a Member State (e.g. French law on PFAS) | National law | Depending on the national text concerned |
The thresholds, scope and deadlines of each framework must be checked in the official texts, according to your use category. No file should rely on a value quoted from memory.
Four frameworks, four possible types of evidence. Rather than multiplying collections, pool the data: a well-collected composition declaration can feed several requirements at once.
A one-off PFAS file can be managed by hand. A portfolio of references, across several suppliers and several versions, cannot. Four building blocks make the difference.
Link each product reference to its supplier, its components, its documents and their deadlines. The goal: find the PFAS status of a given packaging item in a few minutes - without digging through a folder tree.
Evidence has a date. Tracking deadlines and sending reminders before expiry avoids basing a decision on obsolete data - the blind spot described above.
A supplier portal offers a single channel to request, receive and update declarations. It replaces the succession of emails and creates a record of who provided what, when, and for which reference.
A spreadsheet does not natively handle:
A spreadsheet can get a collection started. It cannot carry the PFAS compliance of a packaging portfolio over several update cycles.
A platform centralising supplier and product data makes it possible to collect data through a single channel, structure it by reference, track update deadlines and process documents with AI to extract critical information.
Tracklab follows this approach. It is neither an ERP, nor a production or inventory management tool, nor a regulatory watch tool.
The broader foundation - composition and supplier data for the packaging sector - serves the PPWR, EPR and, for wood and paper packaging, the EUDR.
PFAS compliance is an exercise in documentary traceability. The collection channel, deadline alerts and the link to the product reference matter more than the regulatory threshold itself.
PFAS compliance does not depend on reading the text, but on three decisions:
The concrete next step: pick a packaging reference at random and check whether you can find, in a few minutes, its composition, its PFAS status and the date of the latest supplier declaration. If the answer is no, that is the first project to open - before the PPWR deadlines make it mandatory.
PFAS thresholds, total fluorine tests, statements: the collection kit contains the questionnaire and evidence matrix to obtain these from your suppliers.
The step-by-step method to obtain PPWR evidence from your suppliers (PFAS, substances, recyclability, recycled content), with the questionnaire and evidence matrix ready to send.
All the deadlines of Regulation (EU) 2025/40 on a single timeline, and the checklist of actions to start now, article by article.
Enter your details to access the download immediately.
The files open in Google Drive. For the spreadsheet, Google offers to make a copy in your own Drive.
Not in general. The PPWR provides for a specific restriction on packaging intended for food contact, with limits and a justification requirement. Other frameworks, such as REACH restrictions or national texts, may apply depending on the substance and the use. The exact scope must be checked in the texts in force, according to your product.
In practice, the evidence goes back up the chain: the material supplier, the packaging manufacturer and, where applicable, the component supplier. The company placing products on the market must be able to produce this evidence for the packaging it places on the market, including for components it does not buy directly.
No, not on its own. A generic certificate or statement can only be used if it identifies the product reference, the scope, the date, the version and the method. A commercial claim without these elements does not constitute evidence that can be relied on.
Three levers: write the declaration obligation into the contract, make listing conditional on the data being provided, and document the refusal. A supplier that cannot declare its composition transfers the risk to your file - it is a selection criterion, not just an administrative irritant.
Yes. As soon as a packaged product is placed on the EU market, the requirements apply, whatever the origin of the packaging (see our PPWR FAQ). The importer bears a responsibility comparable to that of the company placing products on the market, which means collecting data from suppliers that are sometimes outside the EU.
It is among the most exposed, not because paper intrinsically contains PFAS, but because certain grease-resistant or moisture-resistant treatments have historically contained them. The answer therefore depends on the treatment applied, to be documented component by component.
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