PFAS Restrictions in Food Packaging Materials
PFAS are a large group of synthetic chemicals known as per- and polyfluoroalkyl substances. These chemicals have historically been used in food packaging materials to provide grease, oil, and water resistance. Common applications include fast-food wrappers, microwave popcorn bags, bakery papers, and paper-based take-out containers.
For stakeholders across the food packaging supply chain, including manufacturers, importers, retailers, and food brands, compliance with PFAS restrictions has become an essential component of food contact materials (FCM) safety management. Regulatory frameworks increasingly require careful control of raw materials, manufacturing processes, supplier documentation, and laboratory testing. Companies that fail to address PFAS restrictions may face regulatory enforcement, product recalls, import rejections, and reputational risk.
This guide explains how PFAS are used in packaging, which materials are affected, the key regulatory requirements across major markets, and how companies can ensure compliance through testing and supplier management.
Understanding PFAS in Food Packaging Materials
PFAS compounds are characterized by strong carbon–fluorine bonds, one of the most stable chemical bonds in organic chemistry. This structure gives PFAS substances unique properties, including resistance to heat, oil, grease, and moisture.
Because of these properties, PFAS have historically been used in grease-resistant coatings and barrier treatments for certain food packaging materials. These treatments help prevent oils and fats from penetrating packaging surfaces while maintaining the structural integrity of paper or fiber-based packaging during food contact.
PFAS treatments have commonly been applied to packaging products such as:
- Fast-food wrappers
- Microwave popcorn bags
- Paperboard take-out containers
- Pizza boxes
- Bakery papers and liners
- Disposable food service packaging
- Molded fiber food trays
In many cases, these coatings are applied to paper and molded fiber packaging materials to improve oil resistance and moisture protection.
Regulatory concern arises because PFAS compounds may migrate from packaging materials into food. Many PFAS substances are highly persistent and may accumulate in environmental and biological systems. As a result, regulatory authorities increasingly restrict PFAS use in food contact materials as part of broader chemical safety policies.
Why PFAS Are Restricted in Food Contact Materials
Regulatory attention surrounding PFAS primarily relates to several characteristics that distinguish them from many other industrial chemicals.
Environmental Persistence
PFAS compounds degrade extremely slowly in natural environments. Once released, they may remain in soil and water systems for extended periods. This persistence has resulted in widespread environmental detection in some regions.
Bioaccumulation
Certain PFAS compounds accumulate in human and animal tissues. Monitoring studies have identified measurable PFAS concentrations in blood samples across multiple populations.
Potential Health Concerns
Scientific research continues to evaluate potential health impacts associated with PFAS exposure. Some PFAS compounds have been associated with possible effects on immune response, developmental processes, and metabolic systems.
Because of these characteristics, regulators increasingly apply precautionary chemical management policies to PFAS in food packaging applications.
Types of Food Packaging Materials Affected by PFAS Regulations
PFAS restrictions primarily affect fiber-based food packaging, although other packaging structures may also fall within regulatory scope depending on formulation and barrier design.
Paper and Paperboard Food Packaging
The most common historical use of PFAS in packaging involves grease-resistant treatments applied to paper products used for food service applications.
Examples include:
- Sandwich wrappers
- Burger wraps
- French fry cartons
- Bakery liners
- Take-away food containers
- Paper plates and bowls
These coatings prevent oils and fats from penetrating the paper surface.
Molded Fiber Food Containers
Molded fiber trays and clamshell containers used for food service packaging may contain additives designed to improve water or grease resistance.
Microwave Food Packaging
Certain microwaveable packaging materials historically used PFAS coatings to maintain grease resistance under high temperature conditions.
Composite Packaging Structures
Some laminated packaging materials combine paper with plastic or barrier layers. PFAS compounds may be used in certain barrier formulations depending on packaging design.
Companies involved in food packaging manufacturing, sourcing, or importing must determine whether PFAS treatments are present in any materials used in the packaging structure.
Global PFAS Restrictions for Food Packaging Materials
Regulation of PFAS in food packaging varies by jurisdiction. Several major markets have implemented restrictions or regulatory phase-outs affecting packaging manufacturers and food brands.
United States
In the United States, PFAS regulation for food packaging involves both federal oversight and state-level legislation.
The U.S. Food and Drug Administration (FDA) previously authorized several PFAS substances for grease-proofing applications in paper and paperboard food contact materials through the Food Contact Notification (FCN) program.
Beginning in 2020, manufacturers voluntarily withdrew several PFAS-related Food Contact Notifications in coordination with the FDA as part of an industry phase-out of these substances.
In February 2024, the FDA confirmed that PFAS grease-proofing agents used in food packaging are no longer being sold for food contact applications in the U.S. market.
In January 2025, the FDA further determined that 35 PFAS-related Food Contact Notifications are no longer effective, with a limited transition period for certain existing paper food packaging until June 30, 2025.
In addition to federal developments, several U.S. states have enacted their own PFAS restrictions for food packaging.
Examples include:
- California
- New York
- Washington
- Vermont
- Maine
- Colorado
State requirements vary. Some states prohibit intentionally added PFAS in food packaging, while others apply additional thresholds based on total organic fluorine measurements for certain packaging materials.
This list is not exhaustive, as PFAS regulations continue to expand in additional U.S. jurisdictions.
European Union
The European Union regulates food packaging materials through several overlapping regulatory frameworks.
The general safety requirements for food contact materials are established under Regulation (EC) No 1935/2004, which requires that materials do not transfer substances to food in quantities that could endanger human health.
PFAS restrictions affecting packaging also arise under the REACH Regulation, which controls certain PFAS substances including perfluorooctanoic acid (PFOA) and related compounds.
In addition, the European Union has adopted the Packaging and Packaging Waste Regulation (Regulation (EU) 2025/40).
The regulation entered into force in February 2025 and introduces restrictions on PFAS in packaging that become applicable starting in August 2026.
Under this regulation, PFAS in packaging materials are controlled through concentration thresholds including:
- 25 ppb for any individual non-polymeric PFAS
- 250 ppb for the total sum of PFAS measured through targeted analysis
- 50 ppm total fluorine, which serves as a screening threshold and may trigger additional documentation requirements to demonstrate the source and quantity of fluorinated substances present.
Companies supplying packaging materials to the EU market must therefore evaluate compliance with both food contact material safety requirements and broader chemical restrictions under REACH and the PPWR.
Denmark
Denmark implemented one of the earliest national bans targeting PFAS in food packaging.
Danish legislation prohibits the use of PFAS in paper and cardboard food contact materials unless a functional barrier prevents migration into food.
Manufacturers supplying packaging materials to Denmark must confirm that PFAS substances have not been intentionally added during production.
Canada
Canada regulates food packaging materials through Health Canada’s Food and Drugs Act and the Food Packaging Materials and Incidental Additives framework.
Food packaging materials are subject to safety evaluation, and manufacturers may obtain a Letter of No Objection from Health Canada following a pre-market safety assessment.
Canada is also conducting broader risk management evaluations for PFAS substances under national chemical management programs.
Companies exporting packaging materials to Canada must ensure that materials comply with food packaging safety requirements and applicable chemical regulations.
Asia-Pacific Markets
Regulatory approaches to PFAS in food packaging across Asia-Pacific jurisdictions vary significantly.
Countries including China, Japan, and South Korea regulate food contact materials through national standards governing substance restrictions, chemical composition, and migration limits.
PFAS-specific controls may arise through broader chemical safety regulations, environmental restrictions, or updates to food contact material standards.
Manufacturers exporting packaging into Asia-Pacific markets should verify requirements on a country-by-country basis.
Testing Methods for PFAS in Food Packaging Materials
Laboratory testing plays an essential role in verifying compliance with PFAS restrictions.
Testing strategies often involve both screening techniques and targeted chemical analysis.
Fluorine Screening Methods
Screening methods such as total fluorine (TF) or total organic fluorine (TOF) analysis measure the presence of fluorinated compounds within a material.
Because PFAS substances contain fluorine atoms, these screening techniques can indicate the potential presence of fluorinated chemicals.
These methods are often used as initial screening tools before more detailed chemical analysis.
Targeted PFAS Analysis
Targeted chemical analysis identifies specific PFAS compounds using advanced analytical techniques such as:
Liquid chromatography coupled with tandem mass spectrometry (LC-MS/MS).
This method allows laboratories to detect and quantify individual PFAS substances at very low concentrations.
Targeted testing is typically required when regulatory limits apply to specific PFAS compounds.
Migration Testing
Migration testing evaluates whether substances transfer from packaging materials into food or food simulants under defined conditions.
Migration testing forms part of many food contact material compliance assessments and may be required for regulatory documentation.
Supplier Due Diligence and Documentation
PFAS compliance depends heavily on supply chain management.
Companies sourcing food packaging materials should request documentation confirming that PFAS substances have not been intentionally added.
Typical compliance documentation may include:
- Material declarations
- Chemical compliance statements
- Laboratory test reports
- Supplier compliance certificates
Supplier audits may also be used to verify manufacturing processes and raw material controls.
Design Alternatives to PFAS-Based Packaging
As regulatory pressure increases, packaging manufacturers are developing PFAS-free barrier technologies.
Examples include:
- Water-based grease barrier coatings
- Wax coatings
- Bio-based polymer coatings
- Mechanical barrier layers
- Fluorine-free laminated structures
These materials provide grease resistance and moisture protection without using fluorinated chemicals.
Food brands increasingly specify PFAS-free packaging requirements in procurement contracts and supplier agreements.
Compliance Strategies for Manufacturers and Importers
Organizations involved in food packaging manufacturing or sourcing should implement structured compliance procedures.
Material Risk Assessment
Review packaging formulations and raw materials to identify potential PFAS sources.
Supplier Verification
Obtain supplier declarations and supporting compliance documentation.
Laboratory Testing
Conduct independent testing when supplier documentation alone cannot confirm compliance.
Regulatory Monitoring
Track regulatory developments in target markets to ensure continued compliance.
Documentation Management
Maintain records demonstrating compliance with food contact material regulations.
PFAS restrictions in food packaging materials have become an important compliance issue across global markets. Packaging manufacturers, food brands, and importers must determine whether fluorinated substances are present in packaging materials, verify supplier documentation, and conduct appropriate laboratory testing.
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