PFAS in Food-Contact Packaging: The 25 / 250 / 50 Thresholds

Food-contact packaging containing PFAS at or above the threshold values may not be placed on the market from 12 August 2026. The thresholds run at three levels of measurement. Any individual PFAS: 25 parts per billion. The sum of PFAS, excluding polymeric PFAS: 250 ppb. PFAS in total, including polymeric PFAS: 50 parts per million. And behind them sits the screening rule of practice: where total fluorine exceeds 50 ppm, the manufacturer must be able to evidence, in the technical documentation, that the fluorine does not come from PFAS.

These are market-access prohibitions with analytical chemistry attached. A line's position is therefore a laboratory fact plus a paper trail, and both halves belong in the technical file.

The three levels exist because PFAS are a family of thousands, measured in different ways. The individual threshold catches named, analysable substances at trace levels. The sum threshold catches the family's cumulative presence excluding polymers, which are measured differently and behave differently. The total threshold catches the polymeric fraction - fluoropolymer coatings and processing aids - that the ppb analyses miss. Total fluorine is the cheap screen over all of it: fluorine in packaging comes overwhelmingly from PFAS where it appears at these levels, so a total-fluorine result under 50 ppm closes the question for most lines, and a result above it opens the documented-proof pathway the regulation provides.

Understanding the logic prevents the standard error: commissioning a targeted PFAS panel (which measures a few dozen named substances) and treating a clean panel as a clean position. The panel cannot see polymeric PFAS; the thresholds can fail without any named substance appearing.

The thresholds attach to packaging intended to come into contact with food - within the meaning the food-contact framework gives that phrase, which includes materials reasonably expected to touch food or transfer constituents to it. The greaseproof wrap, the moulded-fibre bowl, the coated board tray, the fast-food carton: the population is the takeaway and fresh-food shelf first, which is precisely where PFAS were used - for grease resistance. Non-food-contact packaging is outside this threshold family (the general minimisation duty still applies to it), and mixed lines should be classified component by component: a food-contact inner layer inside a non-contact outer carries the thresholds on the component that touches the food.

Per food-contact line, the file should hold: the supplier's PFAS declaration in the form the substances station's declaration guide prescribes - naming intentional use (none), the thresholds, and the basis of knowledge; total-fluorine screening results for the line's materials, dated and method-referenced; targeted analysis where screening or use-history raises questions; and the change-notification clause that makes the supplier's reformulation your information rather than your surprise. Lines with a grease-resistance function deserve the deepest file: the function was PFAS's packaging job, and legacy specifications in greaseproof papers and moulded fibre are where the findings concentrate.

The prohibition attaches to placing from 12 August 2026, under the transition logic the timeline station works through: stock placed before the date is judged by its day's law, unplaced stock meets the thresholds whenever it moves. For food-contact lines with slow stock turns - seasonal packaging, catering disposables in distribution - the screening programme should have run against warehouse stock, not only against current production, because the placing line runs through the warehouse. A business that screened its factory and not its distributor's shelf holds half a position.

Several member states regulated PFAS in food-contact paper and board before the Union thresholds landed - Denmark's prohibition on PFAS in paper and board food-contact materials, in force since 2020, is the documented forerunner, and its enforcement experience taught the market two lessons the Union system inherits. First, the indicator approach works: Denmark policed a total-fluorine indicator value and treated exceedance as evidence of treatment, which is the screening logic Article 5's structure now generalises. Second, supply adapted: grease-resistance without PFAS - mechanical, mineral and alternative-chemistry routes - reached the market at commercial scale within the ban's first years. Lines still specifying PFAS greaseproofing in 2026 are not facing an unsolved technical problem; they are facing a purchasing decision their competitors in the Danish market made years ago.