PPWR PFAS limits and testing: what applies?

When an EU buyer asks you for PFAS and heavy metal test reports, the basis is Article 5 of Regulation (EU) 2025/40. This article covers what it says, how compliance is shown and what the Commission's guidance recommends, keeping the two apart. The information was read from the sources on 13 October 2026.

What are the PPWR PFAS limits?

Food-contact packaging may not be placed on the market if it contains PFAS at or above the following values (Art. 5(5)):

The Commission's guidance equates ppb with µg/kg and ppm with mg/kg. PFAS means any substance with at least one fully fluorinated methyl or methylene carbon atom, apart from structures listed in the definition (Art. 5(5)). The limit applies unless another Union legal act already prohibits placing that packaging on the market.

Which packaging do the PFAS limits apply to?

Food-contact packaging only (Art. 5(5)). According to the Commission's guidance, that is packaging intended to come into contact with food, or already in contact with it for that purpose, as per the scope of EU food legislation.

According to Türkiye's Ministry of Trade:

• Intentionally added and unintentionally present PFAS are treated alike.
• The whole packaging unit counts, including inks, varnishes, glues and adhesives.
• No general criteria separate direct from indirect food contact. It is settled case by case from the intended use.

What is the heavy metal limit, and which packaging does it cover?

Four metals are counted together: lead, cadmium, mercury and hexavalent chromium. The sum of their concentrations resulting from substances present in packaging or packaging components may not exceed 100 mg/kg (Art. 5(4)). The limit is for the four combined.

According to Türkiye's Ministry of Trade, it applies to all packaging regardless of material or use, including wooden pallets, stretch film and strapping. Annex XVII to Regulation (EC) No 1907/2006 and Regulation (EC) No 1935/2004 on food-contact materials apply in addition (Art. 5(4)).

Since when have these limits applied?

The PFAS limits apply to food-contact packaging placed on the market from 12 August 2026 (Art. 5(5)). The heavy metal limit has applied since 12 August 2026, the general date of application (Art. 71). It maintains a restriction that already existed (recital 25).

For PFAS, the Commission's guidance adds:

• There is no transitional period for exhausting stocks. Packaging placed on the market before 12 August 2026 may remain there.
• In general, sales and grouped packaging are placed on the market when filled, transport and service packaging when empty.
• For imports, the relevant moment is release for free circulation at customs.

How do you demonstrate compliance?

Compliance with both limits is demonstrated in the technical documentation (Art. 5(6)). The manufacturer draws it up, with test reports among its elements (Annex VII, point 2), and declares conformity on its sole responsibility (Art. 38, Annex VII).

The Regulation also ties an information duty to the 50 ppm threshold. If total fluorine exceeds 50 mg/kg, the manufacturer, importer or downstream user under Regulation (EC) No 1907/2006 must, upon request, give the packaging manufacturer or importer proof of how much of the fluorine is PFAS or non-PFAS, for the technical documentation (Art. 5(5)(c)). This is a provision of the Regulation. See also What is PPWR?

What does the Commission's guidance say about total fluorine?

The guidance notice C(2026) 3702 recommends a stepwise approach for enforcing the PFAS limits:

1. Total fluorine is quantified. Below 50 mg/kg, the sample could be considered compliant.
2. Above 50 mg/kg, methods such as pyrolysis-GC/MS can confirm whether the fluorine is organic (PFAS) or inorganic. If organic fluorine is below 50 mg/kg, the sample could be considered compliant.
3. Direct TOP (total oxidizable precursors) analysis is recommended to check the 25 and 250 µg/kg limits.

The guidance adds that, on the Commission's current evidence, all samples passing the first test also pass the other two.

This is a recommendation in guidance, not a provision of the Regulation. The guidance itself says it does not replace, add to or amend the provisions of the PPWR, which alone establish the legal obligations. The Regulation has no rule that total fluorine below 50 mg/kg means compliance. Its three thresholds each apply.

Is there a harmonised PFAS test method?

No. According to the guidance, there is no harmonised methodology for PFAS in food-contact packaging at EU level. According to Türkiye's Ministry of Trade, the Commission is working on one, and the Regulation prescribes no single laboratory method.

For the four heavy metals, the Ministry's note says the Commission recommends CEN Report CR 13695-1/2000.

What should you agree with your laboratory and your buyer?

According to Türkiye's Ministry of Trade, no particular laboratory or notified body is required. ISO/IEC 17025 is not mandatory, but an accredited laboratory is recommended, preferably with the method in its scope. Settle first:

• Which steps will be run: total fluorine, targeted analysis, TOP analysis?
• Which packaging type, material and production batch does the report cover?
• Are inks, varnishes and adhesives in the sample?
• Which method and report format does your buyer accept?

According to the Ministry's note, a test per product code is not expressly required. Packaging with the same material and process can be grouped into families, with the technical documentation naming the product tested and why its result applies to the rest. A change in material, coating, print, adhesive or process means reassessing test coverage.

What do you ask your supplier for?

A supplier gives the manufacturer all the information and documentation needed to demonstrate conformity, in a language it can easily understand, on paper or electronically (Art. 16(1)). For contact-sensitive packaging this includes the documentation required under the applicable Union acts (Art. 16(2)).

According to Türkiye's Ministry of Trade, you can ask for material composition, data sheets, heavy metal and PFAS analyses, laboratory reports and supplier statements. A general "complies with PPWR" letter may not be enough: it should name the packaging, material, production series and requirement covered. It does not replace the manufacturer's own assessment.

Are there exemptions or derogations?

Their conditions are in the decisions themselves, not reproduced here.

The Registamp PPWR module checks the measurements you enter against these limits, links the laboratory report to its packaging and adds it to the technical documentation. See the PPWR module page.

This article is general information, not legal advice. For your own case, refer to the text of the Regulation and, where needed, to a specialist.

Sources

• Regulation (EU) 2025/40 on packaging and packaging waste: eur-lex.europa.eu/eli/reg/2025/40/oj
• European Commission guidance notice, C(2026) 3702 final, 5 June 2026: EUR-Lex
• Ministry of Trade of Türkiye, PPWR announcement and information note, 3 August 2026 (in Turkish): ticaret.gov.tr