EU Packaging Regulation introduces PFAS limits and new compliance rules

The European Union's Packaging and Packaging Waste Regulation (PPWR) entered into force on August 12, 2026, introducing strict new requirements for food contact packaging. A primary focus is the restriction of per- and polyfluorinated alkyl substances (PFAS). To comply, packaging must not exceed specific thresholds: 25 µg/kg for any single analyzed PFAS, 250 µg/kg for the sum of non-polymeric PFAS, and 50 mg/kg for total PFAS including polymers.

These regulations apply regardless of material type and encompass not only the packaging itself but also inks, lacquers, adhesives, plastic layers, and additives. Compliance is complicated by the fact that PFAS can enter products through raw material impurities or recycling streams, even if not intentionally added.

The regulation has drawn criticism from the Central Association of German Crafts (ZDH), which describes the administrative burden as “bureaucratic madness.” The association argues that Extended Producer Responsibility (EPR) requirements—such as appointing authorized representatives and managing registration in every EU member state—impose disproportionate costs on small businesses, such as bakers and jewelers, who ship small or seasonal quantities across borders. The ZDH is calling for practical solutions, including de minimis thresholds for smaller enterprises.