PFAS Restrictions in Food Packaging Materials

PFAS, or per- and polyfluoroalkyl substances, are a large group of synthetic chemicals characterized by strong carbon–fluorine bonds that provide resistance to heat, oil, grease, water, and chemical degradation. These properties have supported their use in a wide range of industrial applications, including food packaging materials.

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Use of PFAS in Food Packaging Materials

In food packaging applications, PFAS have been used to enhance the performance of materials that come into contact with oily or high-moisture food products.

Typical applications include:

• Fast-food wrappers
• Microwave popcorn bags
• Paperboard takeaway containers
• Bakery liners and greaseproof papers
• Molded fiber trays
• Disposable food service packaging

These coatings help maintain packaging integrity during food contact while reducing oil and moisture penetration.

Regulatory concern arises because PFAS compounds may migrate from packaging materials into food. In addition, many PFAS substances are highly persistent and may accumulate in environmental and biological systems, leading to increased regulatory control across multiple markets.

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Why PFAS Are Restricted in Food Contact Materials

Regulatory frameworks restrict PFAS based on several key characteristics:

Environmental Persistence

PFAS degrade very slowly in natural environments and can remain in soil and water systems for extended periods.

Bioaccumulation

Certain PFAS compounds accumulate in human and animal tissues, with measurable levels detected in population studies.

Potential Health Concerns

Scientific research has evaluated associations between PFAS exposure and effects on immune function, development, and metabolic processes.

Because of these factors, regulators apply precautionary controls to limit PFAS use in food contact materials.

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Types of Food Packaging Affected by PFAS Regulations

PFAS restrictions primarily affect fiber-based and coated packaging materials, although other structures may also fall within scope.

Paper and Paperboard Packaging

• Sandwich and burger wraps
• French fry cartons
• Paper plates and bowls
• Pizza boxes

These materials often use grease-resistant coatings.

Molded Fiber Packaging

• Clamshell containers
• Food trays

Additives may be used to improve moisture and oil resistance.

Microwave Food Packaging

• Popcorn bags
• Heat-resistant paper packaging

These applications require stable grease barriers under high temperatures.

Composite Packaging Structures

• Laminated paper-plastic materials
• Multi-layer barrier packaging

PFAS may be present depending on barrier formulation.

Companies must determine whether PFAS are present in any layer of the packaging structure.

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Global PFAS Regulations for Food Packaging Materials

United States PFAS Regulations for Food Packaging

PFAS regulation in the United States involves both federal and state-level controls.

• The U.S. FDA previously authorized PFAS substances through the Food Contact Notification (FCN) program.
• Since 2020, manufacturers have voluntarily withdrawn PFAS-related FCNs.
• In 2024, the FDA confirmed that PFAS grease-proofing agents are no longer sold for food contact use.
• In 2025, 35 PFAS-related FCNs were declared no longer effective, with transition deadlines.

State-level regulations further restrict PFAS:

• California
• New York
• Washington
• Vermont
• Maine
• Colorado

Many states prohibit intentionally added PFAS in food packaging.

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European Union PFAS Requirements for Packaging

The European Union regulates PFAS under multiple frameworks:

• Regulation (EC) No 1935/2004 for food contact materials
• REACH Regulation for chemical restrictions
• Packaging and Packaging Waste Regulation (EU) 2025/40

Under the PPWR, PFAS limits include:

• 25 ppb for individual PFAS
• 250 ppb for total targeted PFAS
• 50 ppm total fluorine (screening threshold)

These limits apply from August 2026 and require testing and documentation to demonstrate compliance.

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Other International Markets

Denmark

• Prohibits PFAS in paper and cardboard food packaging unless a functional barrier prevents migration.

Canada

• Regulates packaging through Health Canada safety assessments.
• Requires evaluation of chemical safety and potential migration.

Asia-Pacific

• Regulations vary by country.
• PFAS may be controlled through food contact material standards and chemical regulations.

Companies exporting globally must verify requirements for each destination market.

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PFAS Limits and Thresholds in Packaging Materials

Regulatory thresholds determine whether packaging materials are compliant.

Common parameters include:

• Individual PFAS concentration limits
• Total PFAS concentration limits
• Total fluorine screening thresholds

Total fluorine is often used as a screening tool. Exceeding screening thresholds may trigger further investigation or targeted analysis.

Understanding the difference between screening and targeted limits is essential for compliance planning.

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How to Test PFAS in Food Packaging Materials

Laboratory testing is required to verify compliance with PFAS restrictions.

Fluorine Screening Methods

• Total Fluorine (TF)
• Total Organic Fluorine (TOF)

These methods detect the presence of fluorinated compounds and are used as initial screening tools.

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Targeted PFAS Analysis

• Liquid Chromatography–Mass Spectrometry (LC-MS/MS)

This method identifies and quantifies specific PFAS compounds at low concentrations. It is required when regulatory limits apply to individual substances.

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Migration Testing

Migration testing evaluates whether substances transfer from packaging into food or food simulants under defined conditions.

This is often required to demonstrate compliance with food contact material safety regulations.

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When PFAS Testing Is Required for Food Packaging

Testing should be conducted under the following conditions:

• Exporting packaging to regulated markets such as the EU or U.S.
• Supplier documentation does not clearly confirm PFAS absence
• New materials or coatings are introduced
• Customer specifications require PFAS-free verification
• Compliance audits or regulatory inspections are conducted

Testing provides objective evidence to support compliance claims.

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PFAS Compliance Documentation Requirements

Companies must maintain documentation to demonstrate compliance.

Typical documentation includes:

• Declaration of non-intentionally added PFAS
• Laboratory test reports (TF and targeted PFAS)
• Material composition disclosures
• REACH compliance statements
• Food contact compliance declarations

Incomplete documentation may result in import delays or regulatory action.

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Common PFAS Compliance Failures in Food Packaging

Several recurring issues lead to non-compliance:

• Relying solely on supplier declarations without testing
• Using total fluorine results as final compliance evidence
• Misinterpreting regulatory thresholds
• Assuming historical approvals remain valid
• Lack of updated documentation

These gaps can lead to regulatory enforcement or product rejection.

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Implement a structured PFAS compliance program that combines supplier control, laboratory testing, and regulatory verification. Engage qualified testing and inspection partners to ensure packaging materials meet current global requirements before market entry.