PPWR Article 5: PFAS limits and substances of concern in packaging
In short: Since 12 August 2026, PPWR Article 5 bans food-contact packaging that contains PFAS at or above three limits: 25 ppb for any single PFAS, 250 ppb for the sum of PFAS, and 50 ppm for all PFAS including polymers. For all packaging, the sum of lead, cadmium, mercury and hexavalent chromium must stay below 100 mg/kg. Article 5 also requires manufacturers to minimise substances of concern in packaging.
If you sell food-contact packaging in the EU, the PFAS limits already apply. There is no sell-off period for older stock. The Commission recommends starting with a total fluorine test: a result below 50 mg/kg could be considered compliant.
What PPWR Article 5 requires
Article 5 has four obligations. Only one of them is about PFAS.
| Obligation | Applies to | Rule | Source |
|---|---|---|---|
| Minimise substances of concern | All packaging | Presence and concentration minimised, including in emissions, recycled materials and waste outcomes | Art. 5(1) |
| Heavy metals | All packaging | Lead + cadmium + mercury + hexavalent chromium below 100 mg/kg in total | Art. 5(4) |
| PFAS | Food-contact packaging | Three limit values: 25 ppb, 250 ppb, 50 ppm | Art. 5(5) |
| Documentation | Packaging covered by 5(4) and 5(5) | Compliance shown in the technical documentation under Annex VII | Art. 5(6) |
All four apply from 12 August 2026, the date PPWR applies (Article 71).
PPWR PFAS limits for food-contact packaging
Article 5(5) sets three limit values. Food-contact packaging cannot be placed on the market if it contains PFAS at or above any of them.
| Limit | What is measured | Polymeric PFAS | Source |
|---|---|---|---|
| 25 ppb (25 µg/kg) | Any single PFAS, by targeted PFAS analysis | Not counted | Art. 5(5)(a) |
| 250 ppb (250 µg/kg) | Sum of PFAS, by targeted analysis, with prior degradation of precursors where applicable | Not counted | Art. 5(5)(b) |
| 50 ppm (50 mg/kg) | All PFAS | Counted | Art. 5(5)(c) |
Two details decide how you read the table.
25 ppb is a limit per substance, not a total. Each PFAS found by targeted analysis must stay below 25 ppb. The sum of those PFAS must stay below 250 ppb. Both conditions apply at the same time.
Polymeric PFAS are not exempt. Fluoropolymers are left out of the first two measurements, which count individual molecules. They count towards the 50 ppm limit. A fluoropolymer coating or layer is therefore still part of your PFAS assessment.
What counts as PFAS
Article 5(5) defines PFAS as any substance with at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom, with no hydrogen, chlorine, bromine or iodine attached to it. A short list of structures is excluded from the definition. The definition is broad on purpose: it covers thousands of substances, not a fixed list.
PPWR does not list "regulated PFAS species". Targeted analysis covers the substances your laboratory method can quantify. Ask your laboratory which substances its method includes, and record that list in the technical documentation.
What total fluorine has to do with it
Article 5(5)(c) sets a rule for results above 50 mg/kg total fluorine. On request, the chemical supplier must prove how much of that fluorine is PFAS and how much is not. The proof goes to the packaging manufacturer or importer, who needs it for the technical documentation. The supplier here is the REACH manufacturer, importer or downstream user.
A total fluorine result above 50 mg/kg is therefore not automatically a breach. It is a signal that you need the supplier's fluorine breakdown, or a further test, before you can sign the file.
How to test against the Article 5 PFAS limits
PPWR does not prescribe a test method, and there is no harmonised EU method for PFAS in food-contact packaging. The Commission's guidance document (C(2026) 3702) recommends a stepwise approach for enforcement from 12 August 2026:
| Step | Test | Result |
|---|---|---|
| 1 | Total fluorine (TF) | Below 50 mg/kg: the sample could be considered compliant |
| 2 | If TF is above 50 mg/kg: a method such as pyrolysis-GC/MS, to show whether the fluorine is organic (PFAS) or inorganic | Organic fluorine below 50 mg/kg: the sample could be considered compliant |
| 3 | Direct TOP (total oxidisable precursors) analysis | Checks the 25 µg/kg and 250 µg/kg limits |
The guidance adds that, on the evidence available to the Commission, "all samples compliant with test (1) are also compliant with tests (2) and (3)". In practice, a total fluorine result below 50 mg/kg is the first piece of evidence most files need.
Two points to keep in mind:
- The guidance is an interpretation, not the law. The legal limits are the three values in Article 5(5). A market surveillance authority can still test against any of them.
- Record the method. The technical documentation must list the standards and technical specifications used for measurement (Annex VII, point 2(d)) and include the test reports (point 2(f)). Keep the laboratory, method and limit of quantification with each result.
What counts as food-contact packaging
PPWR does not define "food-contact packaging" in Article 3. The Commission's guidance reads it in line with EU food law: packaging "intended to be brought into contact with food or is already in contact with food and was intended for that purpose".
Typical food-contact packaging in scope:
- greaseproof papers and wraps for bakery, butter and fast food;
- moulded fibre bowls, trays and plates;
- paperboard cups and food trays with barrier coatings;
- inner liners and films in cereal, snack and pet food packs;
- closures and seals that touch the food.
The limits apply to the packaging unit as a whole, including inks, coatings and adhesives, whether the PFAS were added on purpose or not. Transport packaging that is not intended to touch food is outside the PFAS limits.
Packaging made before 12 August 2026
PPWR has no transition period for existing stock. According to the Commission's guidance:
- food-contact packaging placed on the market before 12 August 2026 can stay on the market and does not need to be withdrawn;
- packaging placed on the market after that date must meet the PFAS limits, whenever it was produced;
- there are no exceptions for packaging that contains recycled material.
The date that matters is when the packaging is placed on the market. Sales and grouped food-contact packaging are generally placed on the market when they are filled, because sealing can affect compliance. Transport and service packaging are placed on the market empty. For imports, the relevant moment is release for free circulation at customs.
PFAS rules outside PPWR
Article 5(5) applies only "to the extent" that another Union act does not already ban the packaging. Other PFAS rules continue to apply alongside it:
- restrictions under REACH, Regulation (EC) No 1907/2006;
- the POPs Regulation (EU) 2019/1021;
- food-contact rules under Regulation (EC) No 1935/2004.
By 12 August 2030, the Commission must assess whether Article 5(5) should be amended or repealed to avoid overlaps with those acts (Article 5(5), recital 21).
Heavy metals: the 100 mg/kg limit
Article 5(4) caps the sum of lead, cadmium, mercury and hexavalent chromium at 100 mg/kg. The limit applies to all packaging and packaging components, not only food-contact packaging. It applies without prejudice to REACH Annex XVII and, where relevant, food-contact rules.
The Commission may lower the limit by delegated act (Article 5(7)). It may also set conditions for recycled materials and closed-loop systems, and exempt certain packaging types (Article 5(8)). Those delegated acts may only amend the existing derogations in Decisions 2001/171/EC and 2009/292/EC.
What this means for planning: recycled glass, metal and plastic can carry heavy metals from earlier product cycles. If you increase recycled content for Article 7, check the 100 mg/kg sum on the same batches.
Substances of concern
Article 5(1) requires packaging to be made so that substances of concern are minimised. PPWR takes the definition of "substance of concern" from the Ecodesign Regulation (EU) 2024/1781, Article 2(27) (PPWR Article 3(2)).
Article 5(1) does not set a numeric limit. The next steps are set out in Article 5(2) and 5(3):
- By 31 December 2026, the Commission, with the European Chemicals Agency, must report on substances of concern in packaging. The report may list substances and their risks.
- Follow-up can take two routes: new REACH restrictions for substances that mainly affect health or the environment, or restrictions inside the design-for-recycling criteria under Article 6(4) for substances that hinder re-use and recycling.
- Member States may ask the Commission to restrict substances that hinder recycling (Article 5(3)).
By 12 August 2033, the Commission will evaluate whether Article 5 and the design-for-recycling criteria have reduced substances of concern enough (Article 5(9)).
How to document Article 5 compliance
Article 5(6) requires you to show compliance with 5(4) and 5(5) in the technical documentation under Annex VII. That documentation supports the EU declaration of conformity; see our declaration of conformity guide.
For each food-contact packaging unit, keep:
- the materials and components, and which layers touch the food;
- a total fluorine test report, with the laboratory, method and limit of quantification;
- if total fluorine is above 50 mg/kg, the supplier's fluorine breakdown or a further test;
- a heavy metals result or supplier declaration for the 100 mg/kg sum;
- the date of each result, so you can show which batch or specification it covers.
For other packaging, the heavy metals evidence is enough for Article 5(4).
What to ask suppliers now: a total fluorine test report for each food-contact material, a heavy metals test report, and written confirmation that no PFAS are intentionally added. The last item is not a legal test, but it tells you which materials need closer checks.
Penalties
Member States set the penalties for PPWR infringements. They must adopt the rules and notify the Commission by 12 February 2027 (Article 68). The penalties must be "effective, proportionate and dissuasive".
National rules are still being adopted, so we do not list fine amounts here. Packaging that breaks Article 5 cannot be placed on the market (Article 4(1)), whatever the fine. Market surveillance authorities check compliance with the PFAS limits under Regulation (EU) 2019/1020.
Timeline
| Date | What happens | Source |
|---|---|---|
| 31 Dec 2025 | Member States send data on substances that hinder recycling | Art. 5(2) |
| 12 Aug 2026 | PFAS limits and 100 mg/kg heavy metals limit apply | Art. 5(4), 5(5), Art. 71 |
| 31 Dec 2026 | Commission and ECHA report on substances of concern in packaging | Art. 5(2) |
| 12 Feb 2027 | Member States notify their penalty rules | Art. 68 |
| 12 Aug 2030 | Commission evaluates overlap of the PFAS limits with other EU acts | Art. 5(5) |
| 12 Aug 2033 | Commission evaluates Article 5 and design-for-recycling criteria | Art. 5(9) |
Five common PPWR Article 5 mistakes
- Assuming old stock is exempt. There is no sell-off period. Food-contact packaging placed on the market after 12 August 2026 must meet the limits, whenever it was made.
- Reading 25 ppb as a total. It is a limit for each PFAS. The total limit is 250 ppb.
- Treating fluoropolymers as exempt. Polymeric PFAS are excluded from the targeted measurements but count towards the 50 ppm limit.
- Treating Article 5 as a PFAS-only rule. The 100 mg/kg heavy metals limit applies to all packaging, including recycled material.
- Relying on a "PFAS-free" claim. A supplier statement is useful, but the technical documentation needs test reports.
Frequently asked questions
Does PPWR ban PFAS in all packaging?
No. The Article 5(5) PFAS limits apply to food-contact packaging. Other packaging can still fall under REACH restrictions on specific PFAS.
Do the PFAS limits already apply?
Yes. They apply from 12 August 2026. Food-contact packaging placed on the market since then must meet all three limits.
Are fluoropolymer coatings allowed under PPWR?
They are not counted in the 25 ppb and 250 ppb limits, but they count towards the 50 ppm limit for all PFAS. A coating that brings total PFAS to 50 ppm or above is not allowed.
Which test method does PPWR require?
None. The Commission recommends a stepwise approach: total fluorine first, then a test that separates organic from inorganic fluorine, then TOP analysis. A total fluorine result below 50 mg/kg could be considered compliant.
Is there a PFAS exemption for recycled paper or board?
No. The Commission's guidance confirms there are no exceptions for packaging that contains recycled material. The delegated acts under Article 5(8) on recycled materials cover only the heavy metals limit.
Where Carbonorm fits
The Article 5 file depends on test reports from your suppliers. The Carbonorm continuous PPWR compliance platform asks suppliers for them through a secure form, with no account or login needed: the PFAS answers for each limit, the total fluorine figure and the heavy metals test report. It checks each food-contact item against Article 5(5) and keeps each report next to the article it supports. When the Commission adopts acts that change Article 5, we log the change in the public changelog.
A free PPWR audit walks one bill of materials with a regulatory engineer. You leave with the evidence gaps and the article behind each.
Get the PPWR readiness checklist · Book a free PPWR audit
Related guides
- PPWR compliance: the complete guide
- Article 6: design for recycling
- Article 7: minimum recycled content
- PPWR declaration of conformity
- PPWR for manufacturers
- PPWR deadlines: 2026 to 2040
Source: Regulation (EU) 2025/40 on packaging and packaging waste, OJ L, 22.1.2025, Articles 3, 4, 5, 68 and 71, recitals 19–21 and Annex VII; Commission Notice C(2026) 3702, Guidance document for Regulation (EU) 2025/40, section 5. Rule set as of 5 October 2026. The Commission report on substances of concern is due by 31 December 2026; check the change-log for its status.