A morning coffee in a paper cup, a takeaway box at lunch, or a grease-proof wrapper around a burger may look like that they are made of paper as a natural material. Yet, they contain forever chemicals, if not other types of chemicals. The purpose is to make the food packaging resist water, oil and heat.
For years, one group of chemicals has been particularly useful for creating those properties: PFAS, or per- and polyfluoroalkyl substances, often referred to as “forever chemicals.”
On 12 August 2026, a major regulatory change took effect across the European Union. Under the Packaging and Packaging Waste Regulation (EU) 2025/40, food-contact packaging containing PFAS at or above specified concentration limits can no longer be placed on the EU market.
The measure reflects a broader shift in EU chemicals policy: increasingly, the question is not only whether a substance performs a useful function. The question is whether function justifies the long-term environmental and health burden associated with its use.
What are PFAS and why are they used in packaging?
PFAS are a very large class of synthetic fluorinated substances. Many are extremely persistent because of the strength of the carbon-fluorine bond, one of the strongest bonds in organic chemistry.
This persistence is precisely what makes PFAS useful in commercial applications.
In food packaging, certain PFAS have been used to provide:
- resistance to oil and grease;
- resistance to moisture;
- improved durability of paper and fibre packaging; and
- stability under heat.
They have therefore been used in products such as fast-food wrappers, grease-proof papers, takeaway containers, microwave popcorn bags and other fibre-based food packaging. The problem is that the same chemical stability that makes many PFAS technically attractive also makes them difficult to remove once released into the environment. Many PFAS can persist for long periods in water, soil and ecosystems, and some can accumulate in humans and wildlife.
Why are PFAS a concern for human health?
Not all PFAS have the same toxicological profile, however, some of the best-studied PFAS, including PFOA and PFOS, have been associated with important health concerns. Research and regulatory assessments have associated exposure to certain PFAS with:
- increased cholesterol;
- liver effects;
- reproductive and developmental effects;
- pregnancy-related hypertension;
- altered immune response; and
- increased risk of certain cancers.
Food packaging is not the only, or necessarily the largest, source of human PFAS exposure. PFAS can also be present in drinking water, food, consumer products, industrial emissions and contaminated environments. Nevertheless, food-contact packaging represents an exposure pathway that regulators increasingly consider avoidable, particularly where non-fluorinated alternatives can perform the same function.
What does the new EU regulation require?
The EU Packaging and Packaging Waste Regulation introduces specific PFAS concentration limits for food-contact packaging.
The Regulation sets thresholds including:
- 25 ppb for any individually measured targeted PFAS;
- 250 ppb for the sum of targeted PFAS; and
- 50 ppm for total PFAS, including polymeric PFAS, subject to the applicable analytical rules.
Importantly, the restriction applies to packaging placed on the EU market regardless of whether it was manufactured inside or outside the European Union. The European Commission has also clarified that there is no general exemption for packaging manufactured before 12 August 2026 but first placed on the market after that date. Packaging already placed on the market before the deadline may remain there, but new market placement must comply with the new requirements. The same principle applies to recycled material: the presence of recycled content does not exempt food-contact packaging from the PFAS limits.
Why this matters for the circular economy
The PFAS restriction is not only a chemicals-safety measure. It is also relevant to recycling and circularity. Persistent chemicals can move with materials through recycling systems. If PFAS-containing paper or fibre packaging enters recycling streams, those substances may be transferred into recycled materials or residual waste streams. The same problem can arise when contaminated fibre is composted or otherwise introduced into soil-management systems.
This highlights a broader challenge for the circular economy: materials cannot be considered truly circular if substances of concern continue circulating with them. Designing packaging for recyclability therefore requires more than selecting paper instead of plastic or increasing recycled content. Chemical composition also matters.
What should manufacturers and importers do now?
The new rules create practical obligations across the packaging supply chain. Manufacturers, importers and food businesses need reliable information about the chemical composition of the packaging they purchase.
That may require:
- reviewing supplier declarations;
- identifying where fluorinated treatments are used;
- verifying compliance through appropriate testing;
- changing coatings or barrier technologies;
- improving documentation and traceability; and
- ensuring imported packaging meets the same requirements as EU-manufactured products.
Several non-fluorinated alternatives already exist, including modified fibre structures, wax-based coatings and other barrier technologies. However, substituting one chemical with another should not become an exercise in replacing a known problem with a poorly assessed alternative. The objective should be safe and functional substitution, supported by adequate information on chemical composition and performance.
Effective enforcement
PFAS demonstrate a recurring problem in chemicals management. The EU restriction on PFAS in food-contact packaging therefore represents more than a packaging rule.
It reflects a wider policy direction: where highly persistent chemicals are not essential and safer alternatives exist, continued use becomes increasingly difficult to justify.
The next challenge is implementation. Effective enforcement will depend on reliable supplier information, appropriate testing, market surveillance and stronger traceability across international packaging supply chains.
Removing PFAS from food packaging is only one part of a much larger task: ensuring that the materials designed for a circular economy are also chemically safe enough to circulate.
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