The first major compliance milestone under the EU Packaging and Packaging Waste Regulation (PPWR) has now passed. Since August 12, 2026, food-contact packaging placed on the EU market must comply with restrictions on per- and polyfluoroalkyl substances (PFAS).
With no transition period, businesses must be able to demonstrate compliance. Organizations should assess packaging materials, identify potential PFAS risks and secure the testing data needed to demonstrate compliance.
What are the PFAS requirements for food contact packaging?
- Each PFAS (excluding polymeric PFAS): ≤ 25 ppb
- Sum of PFASs (excluding polymeric PFAS): ≤ 250 ppb
- Total PFASs (including polymeric PFAS): ≤ 50 ppm (as total fluorine)
What are the heavy metals requirements for packaging?
For all packaging and packaging components, the combined concentration of heavy metals must not exceed 100 ppm:
- Lead (Pb)
- Cadmium (Cd)
- Mercury (Hg)
- Hexavalent chromium (Cr(VI))
What products are within scope?
While the current PFAS restriction specifically targets food-contact packaging, PPWR as a whole defines packaging more broadly. Under PPWR, packaging is considered to be any item intended for the containment, protection, handling, delivery or presentation of products. The regulation therefore applies to a broad range of packaging formats, including:
- Sales packaging: packaging forming a sales unit for the end user
- Grouped packaging: packaging used to group sales units for the point of sale
- Transport packaging: packaging designed to facilitate handling and transport
- E-commerce packaging: packaging used for online and distance sales deliveries
Businesses must evaluate all relevant packaging formats to understand which specific PPWR obligations apply, including heavy metals limits that apply to all packaging, as well as requirements relating to documentation, recyclability, labeling and other future obligations.
Assessing PFAS risks
PFAS are not always visible, making testing and verification critical. We support businesses through a global network of laboratories and technical experts, helping organizations understand the composition of their packaging materials and generate the data needed to demonstrate compliance with PPWR requirements.
Our services help organizations:
- Identify known and unknown PFAS substances
- Assess compliance with PPWR requirements
- Support REACH and food-contact material obligations
- Generate robust compliance data
- Reduce regulatory and supply-chain risks
Technical documentation, DoC and EPR
PPWR compliance extends beyond testing requirements. Businesses placing packaging on the EU market should also ensure appropriate technical documentation, a Declaration of Conformity (DoC) and applicable Extended Producer Responsibility (EPR) registration obligations are in place. These requirements help demonstrate compliance and support market access across the EU.
Organizations should review their packaging documentation, supplier information and compliance records to identify gaps and ensure supporting evidence is available when required.
Preparing for future PPWR obligations
The PFAS requirements that took effect in August 2026 are only the first stage of PPWR implementation. Additional requirements relating to recyclability, packaging minimization, recycled content, labeling and reuse will be introduced through 2030 and beyond.
Businesses should start assessing packaging performance, safety and recyclability now to understand future compliance impacts and build a practical roadmap for PPWR readiness.
We can help you understand the requirements and timelines, assess your packaging portfolio and develop a practical roadmap for PPWR compliance.
Learn more about PPWR compliance
Our end-to-end solutions support compliance throughout the packaging lifecycle, including:
- PFAS and substances of concern (SoC) testing
- Design for Recycling (DfR) assessments
- Recycled content verification
- Labeling compliance
- Transport and durability testing
- Digital Product Passport (DPP) data management
- EPR registration support
Discover more:
- Visit our PPWR webpage
- Download our EU Packaging and Packaging Waste Regulation (PPWR) brochure
- Read our expert PPWR Q&A
- Watch on demand our past webinar:
- 'Navigating EU PPWR: Practical Testing & Compliance Solutions' - Get practical guidance on how to evaluate packaging against PPWR requirements and how to demonstrate compliance - Watch on demand
IMPACT NOW
PFAS testing is part of SGS's IMPACT NOW for sustainability initiative, which unites all SGS's sustainability solutions under four strategic pillars – climate, nature, ESG assurance and circularity. Together, SGS drives businesses toward meaningful change, helping them to meet rising regulatory and stakeholder expectations. Find out more at www.sgs.com/impactnow
