The regulation entered into force on 11 February 2025; August 2026 is the general application date. That distinction matters because many businesses have treated the deadline as a future policy discussion. It is now a purchasing and documentation issue affecting packaging manufacturers, importers, converters, brand owners and their material suppliers.

“PFAS-free” has become common marketing language, but a claim on a quotation or data sheet is not enough on its own. Buyers need to understand what was tested, which material structure the result covers and whether the supporting documentation matches the packaging that will actually be placed on the market.

The practical question for buyers Can your supplier provide material-specific evidence that supports the finished packaging manufacturer's PPWR conformity assessment—not just a general statement about PFAS?

What Changes on 12 August 2026?

Article 5(5) of Regulation (EU) 2025/40 sets three concentration limits for PFAS in packaging intended to come into contact with food. Packaging cannot be placed on the EU market if it contains PFAS at or above any of these limits:

Measure	Limit	What it covers
Any individual PFAS	25 ppb	Targeted PFAS analysis; polymeric PFAS are excluded from this quantification.
Sum of targeted PFAS	250 ppb	The sum of PFAS measured through targeted analysis, with prior degradation of precursors where applicable; polymeric PFAS are excluded.
PFAS including polymeric PFAS	50 ppm	The broader limit includes polymeric PFAS. If total fluorine exceeds 50 mg/kg, evidence may be needed to distinguish PFAS fluorine from non-PFAS fluorine for the technical documentation.

A common misunderstanding The 50 ppm threshold should not be described simply as a “total fluorine limit.” The legal limit is for PFAS, including polymeric PFAS. Total fluorine can be used as a screening indicator, but fluorine may also come from non-PFAS sources.

The limits apply to food-contact packaging placed on the EU market, regardless of where the Paper or packaging was manufactured.For buyers sourcing from Asia, the commercial implication is straightforward: European market access depends on documentation that can follow the material through the supply chain and support the conformity assessment of the finished packaging.

Compliance Is a Supply-Chain Responsibility

The PPWR assigns different obligations to manufacturers, suppliers and importers. A raw-paper supplier is not automatically the party that issues the EU declaration of conformity for the finished packaging, but it must provide the information needed by the packaging manufacturer to demonstrate compliance.

Manufacturers of packaging

Before placing packaging on the market, manufacturers must carry out the required conformity assessment, prepare technical documentation and, once conformity is demonstrated, draw up an EU declaration of conformity. They must also maintain procedures that keep series production consistent with the approved design and materials.

Suppliers of paper and packaging materials

Suppliers are required to provide the manufacturer with the information and documentation needed to demonstrate conformity. For paper buyers, this makes clear product identification, material composition, test scope and traceability more important than broad portfolio-level claims.

Importers

Importers must check that the manufacturer has completed the conformity assessment and prepared the required technical documentation. This is why European importers are increasingly asking for evidence earlier—during supplier qualification, sampling and contract review rather than after the goods have shipped.

What the PPWR does not say The regulation does not set one universal laboratory report format, require every supplier report to be less than 12 months old, or state that every shipment must be independently retested. Buyers may adopt stricter rules based on product risk, customer requirements and change history, but those are purchasing controls rather than wording taken directly from the regulation.

Which Paper Packaging Products Need the Closest Review?

Not eVery Paper product has the same PFAS risk. Buyers should prioritise materials according to barrier chemistry, intended use and the number of components in the final structure.

Greaseproof paper, food wraps and bags

These products deserve early attention because fluorinated treatments have historically been used in some oil- and grease-resistant Paper Grades. That does not mean every greaseproof paper contains PFAS. Dense fibre structures, mechanical refining, starch-based systems and non-fluorinated barrier technologies can provide grease resistance without intentionally added PFAS.

The buyer should confirm the exact grade, basis weight, KIT level, food application and whether printing, adhesives or additional coatings will be added after the base paper is supplied.

PE-coated cupstock and food board

Polyethylene is not a PFAS chemistry, so a standard PE barrier does not by itself indicate intentional PFAS use. The complete packaging structure still needs review, including the base board, PE resin, printing inks, adhesives, processing aids and any additional functional layer.

For cup and bowl converters, physical consistency remains just as important as chemical documentation. Variations in grammage, moisture, stiffness, coating weight or adhesion can cause poor feeding, curling, seam leakage and unstable performance on high-speed forming lines.

Silicone baking and release paper

A cured silicone release coating is different from a fluorinated grease barrier. Even so, buyers should confirm the full construction, curing system, food-contact documentation and any printing or converting materials used in the finished product. A product description such as “silicone paper” is not a substitute for grade-specific evidence.

Water-based, PLA and other alternative barriers

Alternative coatings can help meet performance or sustainability goals, but the claims must be kept separate. “PFAS-free,” “plastic-free,” “recyclable” and “compostable” describe different attributes and require different evidence. A water-based coating is not automatically recyclable in every collection system, and a PLA-coated board is not automatically certified compostable unless the specific structure has been assessed under the relevant standard.

What Should Be in a Credible PFAS Evidence Pack?

No single document answers every compliance question. A useful evidence pack connects the product identity, chemical assessment and supply-chain controls.

Clear product identification

Grade name, mill or production source, basis weight, coating structure, intended food-contact use and any printing or converting steps covered by the assessment.

A supplier statement on PFAS use

A written statement confirming whether PFAS are intentionally added, with a clear definition and scope. “Fluorine-free” should not be used casually as a synonym for “PFAS-free.”

Relevant analytical evidence

Test reports should identify the sample, test method, laboratory, reporting limits and date. Targeted PFAS analysis and fluorine screening answer different questions; the testing plan should match the material risk.

Food-contact documentation

Declarations and test results appropriate to the target market and material structure, such as applicable EU food-contact requirements, BfR recommendations or US FDA provisions.

Traceability and change control

Batch or lot identification, manufacturing source and a process for notifying buyers when the formulation, coating system, base paper or production site changes.

Performance validation

Samples or pilot quantities for testing grease resistance, sealing, printing and machine runnability before commercial-scale purchasing.

Testing method matters Targeted analysis can quantify specified PFAS but may not capture every unknown or polymeric PFAS. Total fluorine or total organic fluorine can be useful screening tools, but they do not by themselves prove that all detected fluorine is PFAS. The result must be read together with the method, detection limits and material composition.

Five Questions to Ask a Supplier Before Approving a Grade

1. What exactly does your PFAS statement cover?

Ask whether it applies to the named grade, the coating formulation, the complete converted structure or only the base paper.

2. Which test methods were used?

Confirm whether the evidence includes targeted PFAS analysis, precursor treatment, total fluorine or total organic fluorine, and check the reporting limits.

3. Is the report representative of the material we will buy?

The sample description, mill source, coating type and grammage should match the commercial material closely enough to support a risk-based assessment.

4. What happens if the formulation or mill changes?

A supplier should have a change-notification process so that previous documentation is not silently applied to a different material structure.

5. Can we test the material before scaling up?

For greaseproof paper, baking paper and cupstock, laboratory results should be followed by application and converting trials.

A Practical Action Plan Before 12 August 2026

Companies do not need to test every item blindly. A structured review is faster and usually produces better evidence.

Map every food-contact packaging SKU placed on the EU market and identify the legal manufacturer and importer for each one.

Group SKUs by material family and barrier technology: uncoated paper, greaseproof paper, silicone-coated paper, PE-coated board, dispersion-coated board and laminated structures.

Prioritise high-risk items, especially oil- and grease-resistant grades with unclear historical chemistry or incomplete supplier documentation.

Collect product specifications, declarations, food-contact documents and representative analytical reports.

Identify gaps between the tested sample and the commercial packaging, including inks, adhesives, coatings and converting changes.

Run targeted laboratory testing and production trials where the existing evidence does not adequately cover the finished structure.

Create a document-control process so that changes in formulation, mill source or packaging design trigger a review before the next order.

How Sure Paper Supports Food Packaging Buyers

Sure Paper works with converters, distributors and packaging manufacturers on application-based material selection. Instead of treating PFAS-free as a stand-alone sales claim, we review the end use, barrier requirement, converting process and documentation needs before recommending a grade.

PFAS-free greaseproof paper options for food wrapping, bakery liners and grease-resistant bags, with different GSM and KIT requirements available by grade.

Silicone baking and release paper for bakery and food-preparation applications.

One- or two-side PE-coated cupstock in sheets, rolls and bottom reels for cups, bowls and food containers.

Water-based dispersion and PLA-coated options for projects with additional recyclability or compostability objectives, subject to grade-specific documentation.

A4 samples and trial material for laboratory, printing and converting evaluation before larger commitments.

Technical data, food-contact documents and third-party reports available according to the selected grade, mill and order requirements.

Documentation availability varies by material and production source. We confirm the exact report scope, certification status and test requirements during product selection rather than applying one general claim to every grade.

The Deadline Is Close, but the Process Can Be Managed

The PPWR does not make paper packaging procurement impossible. It does make vague specifications and unverified claims harder to defend.

The strongest approach is to start with the finished packaging, identify the materials and economic operators involved, and then build an evidence chain that is specific enough to support conformity. For greaseproof papers, cupstock, baking papers and alternative barrier boards, chemical documentation and converting performance should be reviewed together—not as separate purchasing tasks.

Need to review an existing paper grade or test a PFAS-free alternative? Contact Sure Paper to discuss the food application, paper structure, barrier requirement and documents needed for your market.

REQUEST SAMPLES OR A DOCUMENT REVIEW www.sure-paper.com/contact.html

Frequently Asked Questions

Does FDA compliance prove that packaging meets the PPWR PFAS limits?

No. FDA food-contact compliance and the PPWR PFAS concentration limits address different legal requirements. A product may need evidence for both, depending on where it is sold.

Does FSC or PEFC certification prove that paper is PFAS-free?

No. FSC and PEFC address responsible forest sourcing and chain of custody. They are valuable certifications, but they do not establish chemical compliance.

Is 50 ppm the PPWR limit for total fluorine?

Not exactly. Article 5(5)(c) sets a 50 ppm limit for PFAS, including polymeric PFAS. If total fluorine exceeds 50 mg/kg, evidence may be required to show how much of that fluorine comes from PFAS and non-PFAS sources.

Does PE-coated cupstock need PFAS documentation?

Yes. PE is not a PFAS barrier, but the complete packaging—including base board, coatings, inks and adhesives—must still be assessed and supported by appropriate documentation.

Can PFAS-free greaseproof paper still achieve strong oil resistance?

Yes, depending on the paper design and end use. Mechanical fibre treatment, dense sheet formation and non-fluorinated barriers can provide useful grease resistance, but the actual grade should be tested for the intended food and converting process.

Who should issue the EU declaration of conformity?

The manufacturer of the packaging, as defined by the PPWR, is responsible for the conformity assessment and EU declaration of conformity. Material suppliers support that process by providing the necessary information and documentation.