Why 12 August 2026 Matters for Food Packaging Buyers

For food packaging companies selling into the European Union, 12 August 2026 is more than a regulatory date on the calendar. It changes what buyers, converters, packaging manufacturers and importers need to be able to show about the materials used in food-contact packaging.

Regulation (EU) 2025/40, better known as the Packaging and Packaging Waste Regulation (PPWR), entered into force in February 2025. Most of the Regulation applies from 12 August 2026. From that date, food-contact packaging containing PFAS at or above the limits set in Article 5(5) may not be placed on the EU market, subject to the conditions in the Regulation.

For paper buyers, the practical issue is straightforward: a general statement that a product is ‘PFAS-free’ is no longer enough on its own. The useful question is whether the supplier can provide material-specific information that supports the conformity assessment of the finished packaging.

That matters particularly for grease-resistant papers, coated boards and multi-layer structures where the base paper is only one part of the final packaging system.

The Three PPWR PFAS Limits Buyers Need to Know

Article 5(5) sets three concentration limits for PFAS in food-contact packaging from 12 August 2026:

One point is worth spelling out because it is often simplified incorrectly: 50 ppm is not simply a ‘total fluorine limit’. Total fluorine can be useful as a screening tool, but fluorine may also come from non-PFAS substances. Test results therefore need to be read together with the analytical method and the material composition.

This is why procurement teams should be cautious when a supplier provides only a one-line ‘fluorine-free’ or ‘PFAS-free’ statement without explaining the scope of the declaration or the material that was tested.

Compliance Is a Supply-Chain Responsibility, Not a Paper-Mill Certificate

The PPWR assigns different obligations to different economic operators. Manufacturers of packaging must carry out the applicable conformity assessment and prepare the technical documentation. Suppliers of packaging materials must provide the information and documentation needed for that assessment. Importers must verify that the required conformity procedures and documents are in place before packaging is placed on the EU market.

For a paper buyer, that makes document quality a purchasing issue. A company-wide statement can be helpful, but product-level evidence is more useful when it clearly identifies the paper grade, GSM, coating structure, mill or production source and intended application.

The closer the documentation is to the material actually being purchased, the easier it is for converters and packaging manufacturers to build a defensible compliance file.

Which Food Packaging Papers Deserve the Closest Review?

Not every paper product carries the same risk profile. The most useful way to prioritize a review is to look at the barrier chemistry, the food application and the finished packaging structure.

1. Greaseproof Paper and Food Wraps

Greaseproof paper deserves close attention because fluorinated chemistry has historically been used in some oil- and grease-resistant grades. That does not mean all greaseproof paper contains PFAS. Grease resistance can also be achieved through dense fiber structures, mechanical refining, optimized sheet formation, starch-based systems and other non-fluorinated barrier technologies.

Buyers should confirm the exact grade, basis weight, KIT level, intended food application, production source and barrier technology. If printing, lamination, coating or adhesives will be added later, those steps also need to be considered in the assessment of the finished packaging.

KIT Performance and PFAS Compliance Are Not the Same Thing

KIT testing measures resistance to oil and grease. A higher KIT value can be useful for more demanding food applications, but it does not by itself prove whether PFAS is present or absent.

A well-designed non-fluorinated greaseproof paper can achieve strong grease resistance through its fiber structure and barrier system. The correct purchasing approach is therefore to check two things separately: whether the paper performs in the intended application, and whether the supporting evidence is suitable for the applicable PFAS assessment.

2. PE-Coated Cupstock and Food Board

Polyethylene is not a PFAS chemistry, so standard PE coating does not in itself indicate intentional PFAS use. PE-coated cupstock remains a widely used structure for paper cups, bowls and other liquid-food packaging because it provides moisture resistance, heat-sealing performance and reliable converting behavior.

That said, buyers should not treat the PE layer as proof that the whole packaging structure is compliant. The relevant system may also include the base board, printing inks, adhesives, processing aids and additional functional coatings.

The practical rule is simple: evaluate the structure you will actually place on the market, not just the best-known layer in it.

3. Baking Paper, Silicone-Coated Paper and Alternative Barriers

Baking and release papers, water-based barrier papers and PLA-coated boards are often discussed as alternatives in sustainable packaging projects. They should still be assessed grade by grade. ‘PFAS-free’, ‘plastic-free’, ‘recyclable’ and ‘compostable’ are different claims and should not be treated as interchangeable.

For buyers, the right question is not which label sounds best. It is which structure fits the food application, converting process, target market and documentation requirements.

Chemical Compliance Does Not Replace Converting Performance

A paper can have the right compliance documents and still cause problems on the production line. For cup and bowl manufacturers, consistent grammage, thickness, moisture, stiffness, coating weight, coating adhesion and roll quality remain essential.

Variations can lead to feeding instability, curling, poor side-seam sealing, bottom leakage, wrinkling, printing registration problems and higher waste. For greaseproof papers, poor formation or inconsistent barrier performance can create another set of failures during wrapping, printing and food-contact use.

This is why laboratory documentation should be paired with practical sample testing or production trials whenever the application is critical or the material is new to the converting line.

What a Useful PFAS Evidence Pack Should Contain

There is no single certificate that answers every compliance question. A useful supplier file should connect the identity of the product with its composition, test evidence and traceability.

1. Product identification: Grade name, GSM, mill or production source, coating structure, coating weight and intended food-contact application where relevant.

2. PFAS declaration: A written statement that clearly explains the scope. A declaration covering the specific paper grade and coating structure is more useful than a general company policy statement.

3. Relevant laboratory evidence: The report should identify the tested material, laboratory, method, reporting limits, test date, sample description and the PFAS scope. Targeted PFAS analysis and fluorine screening answer different questions.

4. Food-contact documentation: PFAS compliance is separate from general food-contact compliance. Depending on the application and market, buyers may also need relevant EU food-contact documentation, FDA-related documents, migration data or national recommendations.

5. Traceability and change control: A report is only useful while it remains representative of the commercial material. Buyers should know what happens if the paper mill, coating formulation, production site or other relevant component changes.

Five Questions to Send Your Paper Supplier This Week

What exactly does your PFAS statement cover? Base paper only, coating, complete paper structure, or finished packaging?

Which analytical methods were used? Ask what was tested, the reporting limits and whether the report includes targeted PFAS analysis, precursor treatment where relevant, and/or fluorine screening.

Does the report match the material we will buy? Check grade, mill source, GSM, coating type and production structure.

What happens if the formulation or production source changes? A documented change-notification process is far more valuable than a certificate that is silently carried over to a different material.

Can we run a sample or production trial? For greaseproof paper, baking paper and cupstock, practical converting tests remain an important part of supplier approval.

A Practical Sourcing Check Before 12 August

Step 1 — Map the EU food-contact SKUs: List the packaging products that will be placed on the EU market and identify the finished packaging manufacturer, importer, material suppliers and end-use application.

Step 2 — Group materials by barrier technology: Separate greaseproof, PE-coated, silicone-coated, water-based barrier, PLA-coated and laminated structures rather than reviewing every SKU in the same way.

Step 3 — Prioritize the higher-risk or least-documented items: Start with oil- and grease-resistant grades, unclear coating chemistries, historic fluorochemical treatments and materials with incomplete supplier evidence.

Step 4 — Build the document pack: Collect specifications, PFAS declarations, relevant laboratory reports, food-contact documents, traceability information and FSC/PEFC documents where those certifications are required.

Step 5 — Close the gaps with testing and trials: Where the evidence is not representative of the commercial grade, consider targeted testing and practical converting trials.

Step 6 — Set up change control: A compliant file can become outdated when a mill, coating formulation, production site or packaging structure changes. Define when the documentation must be reviewed again.

How Sure Paper Supports PPWR-Ready Food Packaging Sourcing

At Ningbo Sure Paper, we work with converters, distributors and importers that need to match paper performance with the documentation required by their target market. We do not treat ‘PFAS-free’ as a stand-alone marketing claim; the relevant grade, barrier structure, application and production source all matter.

For greaseproof paper, we can evaluate options according to GSM, KIT performance, food application and available supporting documentation. For PE-coated cupstock, specifications can be matched to cup or bowl dimensions, coating structure, machine requirements and converting conditions. We can also discuss silicone baking paper, water-based barrier paper, PLA-coated board and other application-specific structures where these are relevant to the project.

Documentation availability should always be confirmed against the actual grade and source being offered. Where a buyer needs to qualify a new material, samples can be arranged for laboratory evaluation or production trials before a larger commercial order.

The August 2026 Date Is Also a Supplier-Qualification Deadline

The PPWR does not make food packaging paper sourcing more complicated for the sake of it. It makes vague specifications and unsupported claims harder to rely on.

For buyers, the safest approach is to start with the finished packaging, identify the materials and economic operators involved, and then build a document chain that matches the commercial product. For greaseproof paper, cupstock, baking paper and alternative barrier boards, chemical evidence and converting performance should be reviewed together.

The companies that do this work before approving the next material or shipment will be in a stronger position to manage customer audits, technical changes and EU market requirements without unnecessary disruption.

Frequently Asked Questions

Does FDA compliance prove that a paper meets the EU PPWR PFAS limits?

No. FDA food-contact requirements and the PPWR PFAS limits address different regulatory questions. A material supplied to more than one market may need separate supporting evidence.

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

No. FSC and PEFC relate to responsible sourcing and chain of custody. They do not demonstrate PFAS compliance.

Is 50 ppm the PPWR limit for total fluorine?

Not exactly. The 50 ppm threshold in Article 5(5) concerns PFAS, including polymeric PFAS. Total fluorine can be used as a screening indicator, but the regulation also recognizes that fluorine may come from non-PFAS sources.

Can PFAS-free greaseproof paper still achieve a high KIT level?

Yes. Depending on the grade and barrier technology, strong grease resistance can be achieved without intentionally added PFAS. Performance still needs to be validated for the actual food application.

Is PE-coated cupstock automatically PPWR compliant?

No. PE itself is not PFAS chemistry, but the complete packaging structure and the supporting documentation still need to be assessed.

Who prepares the EU Declaration of Conformity?

Under the PPWR, the packaging manufacturer carries out the applicable conformity assessment and draws up the EU Declaration of Conformity when conformity has been demonstrated. Material suppliers support that process by providing the necessary information and documentation.

Need to Review a Food Packaging Paper Before Ordering?

Send us the food application, current paper grade or specification, required GSM, KIT level if applicable, coating structure, target EU market and the documents you already have.

Sure Paper can help you identify suitable paper options and arrange samples for laboratory or production evaluation before you commit to larger volumes.

Contact: www.sure-paper.com/contact.html

Regulatory Reference

Regulation (EU) 2025/40 on packaging and packaging waste: Article 5(5) (PFAS limits), Article 15 (manufacturers), Article 16 (supplier information obligations) and Article 18 (importers). Always check the current official EUR-Lex text when making legal or compliance decisions.