Mounting evidence on the detrimental health and environmental effects of persistent per- and polyfluoroalkyl substances (PFAS) has led to a tightening regulatory environment over the past years. Food packaging is a key focus of several recent PFAS restrictions, reflecting concerns that the chemicals are transferred from packaging to food and are further ingested by consumers.
This article summarizes PFAS regulations on food packaging and other contact materials in the EU and the US. Compliance testing options, accounting for the technical infeasibility of detecting thousands of PFAS compounds individually, are also discussed.
EU restrictions on PFAS in food packaging
The new EU Packaging and Packaging Waste Regulation (PPWR) bans PFAS in food packaging, based on the reasoning that PFAS exposure through food contact materials presents an "unacceptable risk for human health".1 The ban took effect on August 12, 2026.
The restriction specified in the PPWR prohibits any food packaging that contains PFAS in concentrations at or above the following:
25 ppb for any compound measured with targeted PFAS analysis
250 ppb for the sum of PFAS measured with targeted analysis
50 ppm for total fluorine originating from PFAS sources
The regulation defines PFAS as "any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom (without any H/Cl/Br/I attached to it)," except when they contain certain structural elements.
In June 2026, the European Commission published a guidance document clarifying its current stance on how compliance with the PPWR can be evaluated.2 With regard to the PFAS restriction, the guidance outlines the following stepwise approach:
Total fluorine (TF) analysis to determine whether the 50 ppm limit is exceeded. If TF < 50 ppm, the material can be considered compliant without further testing.
Differentiation between organic and inorganic fluorine in cases where TF > 50 ppm, using a method such as py-GC/MS. If total organic fluorine (TOF) < 50 ppm, the material can be considered compliant without further testing.
If these steps are not enough to demonstrate that PFAS are not present, a direct TOP assay (total oxidizable precursors) is recommended to evaluate compliance with the 25 ppb and 250 ppb limits.
Restrictions on PFAS in food packaging in the US
The U.S. Food & Drug Administration (FDA) announced in February 2024 that food packaging manufacturers had agreed to no longer sell PFAS-containing grease-proof packaging following a voluntary phase-out. The food contact notifications (FCNs) formerly authorizing such use were subsequently withdrawn in January 2025, effectively formalizing the ban.3
Several U.S. states have also introduced their own prohibitions on PFAS in food packaging. These include California, Colorado, Minnesota, New York, and Washington, among others.
Apart from California, the state-level regulations do not outline clear compliance criteria, such as PFAS compounds that should be monitored or concentration limits that should not be exceeded. According to the California Health & Safety Code § 109000, PFAS presence is to be measured as total organic fluorine (TOF), and TOF content must not exceed 100 ppm.4
How can compliance be assessed?
From a compliance testing perspective, the EU PPWR PFAS restriction is reasonably straightforward, as a total fluorine analysis is often sufficient to demonstrate compliance. Also, in cases where the total fluorine content exceeds 50 ppm, Measurlabs can offer the follow-up analyses recommended by the European Commission (i.e., py-GG/MS for TOF analysis and direct TOP assay for targeted PFAS analysis).
The absence of full compliance criteria complicates compliance assessments for the US market. However, our recommended approach of combining TOF analysis with an extended targeted screening of PFAS compounds with LC-MS/MS can be used to show that TOF content falls below the 100 ppm threshold and that the material does not contain high-profile PFAS in detectable amounts, thus showing that the material is effectively PFAS-free.
Measurlabs has extensive experience working with packaging manufacturers to verify compliance with PFAS restrictions. You can get a quote for testing your company’s material by contacting us through the form below. For a customer reference, see this story about how we helped Nordic biobased packaging innovator Sulapac verify the absence of PFAS in their products.
References
1 Paragraph 5 of Article 5 of the PPWR (Regulation (EU) 2025/40) specifies the conditions of the restriction and defines PFAS.
2 See the European Commission's Guidance document on Packaging and Packaging Waste Regulation (PPWR) on EUR-Lex.
3 FDA landing page: Authorized Uses of PFAS in Food Contact Applications. Other contact materials, such as non-stick pots and pans, can still contain PFAS, as the migration potential is low.
4 Assembly Bill No. 1200, adding Chapter 15 (commencing with Section 109000) to the California Health and Safety Code