With the EU's Packaging and Packaging Waste Regulation (PPWR) applying to food contact packaging from 12th August 2026, one phrase has become ubiquitous in conversations between brands, packaging suppliers, and compliance teams: 'PFAS-free.'
It sounds simple. It isn't!
What are PFAS and why do they matter?
PFAS (per- and polyfluoroalkyl substances) are a class of synthetic chemicals used in packaging for their ability to repel oil, water and grease. They're found in food contact materials including fast food wrappers, microwave popcorn bags, takeaway containers and more.
The problem is their persistence. PFAS don't break down in the environment or in the human body, earning them the nickname 'forever chemicals.' A growing body of evidence links certain PFAS to adverse health effects and regulators on both sides of the Atlantic have been tightening restrictions rapidly.
Under the PPWR, strict PFAS thresholds will apply to food contact packaging. In principle, this is exactly the kind of precautionary regulation that protects public health. In practice, compliance is significantly more complicated than switching to a different material.
The testing problem
As highlighted in a detailed piece from Packaging Scotland featuring Peter Tindale of Selig Group, here’s the catch: Total Fluorine Testing which is the primary screening tool currently in use, cannot distinguish between different types of fluorine-containing compounds.
Specifically, it cannot tell the difference between stable, inert fluoropolymers that pose little or no migration risk and the harmful, mobile PFAS that could migrate into food and cause harm.
The practical consequence is troubling. A package could technically fail the total fluorine test and still be entirely safe. Another could pass the test and still pose a genuine risk. For compliance teams trying to make clear-cut decisions on supplier approval, this ambiguity is a serious problem.
What 'PFAS-free' actually requires
True PFAS compliance isn't just a materials switch. It requires a combination of:
The right testing strategy, so understanding which tests are appropriate for which materials and applications, and what the results actually mean
Supplier transparency — full disclosure of the substances present in packaging materials, including those that may not be intentionally added
Solid documentation, in other words a paper trail that can be defended under regulatory scrutiny, including evidence of testing methodology and results
This is exactly why clean, reliable packaging data isn't a nice-to-have in the current regulatory environment, it's essential. Brands and packaging teams that are still relying on informal supplier assurances or incomplete data records are taking on significant compliance risk as the August 2026 deadline approaches.
Data confidence ahead of deadlines
At Reath, we're seeing this play out across our client base. The brands that are best positioned for PPWR compliance and for future regulatory changes beyond PFAS are those that have invested in getting on top of their packaging data now, rather than scrambling reactively as deadlines approach.
That means knowing what's in every component of every SKU, having audit-ready records of material composition, and being able to demonstrate compliance with confidence rather than hope.
The PPWR is one of several major regulatory shifts hitting the packaging industry in 2026 and beyond. The teams that treat each new requirement as an opportunity to build stronger data infrastructure will be far better placed than those treating them as one-off compliance hurdles.
Reath helps brands and packaging teams get on top of their data ahead of EPR and other major regulatory deadlines. Book a conversation with our team at reath.id