PFAS Food-Contact Packaging Testing — PPWR Article 5 Inputs
PFAS testing for food-contact packaging must distinguish compound-specific extraction from fluorine screening and broader PFAS evidence. State the jurisdiction and exact legal or buyer requirement first; an undetected targeted panel does not prove the absence of all PFAS.
What Article 5(5) requires from 12 August 2026
Regulation (EU) 2025/40 prohibits placing food-contact packaging on the market where concentrations meet or exceed 25 ppb for an individual PFAS by targeted analysis, 250 ppb for the sum of targeted PFAS (polymeric PFAS excluded), or 50 ppm for PFAS including polymeric PFAS. The total-PFAS provision and its measurement wording must be read in the operative text. These are food-contact packaging provisions, not a blanket test limit for all materials.
Fluorine screening is not compound identification
Article 5(5) also addresses evidence where total fluorine exceeds 50 ppm: on request, the responsible operator must demonstrate the fluorine measured as PFAS or non-PFAS. Total fluorine can include non-PFAS chemistry; targeted analysis may omit polymers and unlisted compounds. Agree analyte coverage, extraction, limits of quantification and the evidence needed for the broader requirement. Avoid reporting an incomplete panel as 'PFAS-free'.
Account for the finished packaging matrix
Coatings, inks, adhesives and multilayer structures can affect extraction and interpretation. Identify the article placed on the market and whether component tests are for troubleshooting or the required compliance evidence. Ask for matrix validation, blank control, recovery and units on the correct material basis. Keep this assessment separate from migration into food, retailer restrictions and national rules that may have different definitions.
Sample considerations
- Provide the finished article, layer/coat/ink descriptions, intended food-contact use and applicable legal clause.
- Agree component versus whole-article basis, targeted list, polymer coverage and quantification limits below relevant decision thresholds.
- Use provider-agreed PFAS sampling materials and blanks; record handling and supply-chain changes.
Questions to ask a laboratory
- Which Article 5(5) measures does this package cover, and what is excluded?
- How are polymeric PFAS and fluorine from non-PFAS chemistry handled?
- Are matrix recoveries and reporting limits adequate for the stated threshold?
Laboratories with relevant capabilities
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Frequently asked questions
- Does a fluorine screen satisfy a packaging restriction?
- It depends on how the restriction is written. Some programmes accept a total fluorine threshold as evidence that PFAS were not intentionally added; others expect targeted analysis. Check the wording you must comply with, and tell the laboratory which it is.
- Should I test the coating or the whole article?
- Usually the article as supplied, because that is what contacts food. If you are troubleshooting a source, testing components separately can localise the fluorinated chemistry.
Sources and scope references
Related testing briefs
Food Contact & Consumer Product Testing
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