PFAS in Food Packaging: Regulations, Testing, and Compliance Requirements

PFAS in food packaging has become a major compliance concern for manufacturers, importers, retailers, and food service companies worldwide. As governments introduce stricter restrictions on per- and polyfluoroalkyl substances (PFAS), businesses must evaluate whether food packaging materials contain regulated PFAS compounds and ensure compliance with applicable market requirements.

PFAS have historically been used in food packaging because of their ability to resist oil, grease, moisture, and heat. These properties made PFAS useful for grease-resistant paper packaging, takeaway containers, food wrappers, and microwave food packaging. However, increasing regulatory scrutiny has resulted in significant restrictions across multiple global markets.

Why PFAS Are Used in Food Packaging

PFAS are a large family of fluorinated chemicals that provide barrier properties which help food packaging maintain performance during storage, transport, and consumption.

Common packaging applications historically associated with PFAS include:

• Fast-food wrappers
• Burger and sandwich wraps
• French fry cartons
• Paper plates and bowls
• Microwave popcorn bags
• Bakery liners
• Takeaway containers
• Molded fiber food trays
• Grease-resistant paper packaging

These materials often require protection against oils, fats, and moisture, making PFAS-containing coatings attractive for packaging manufacturers.

Why PFAS Are Restricted in Food Packaging

Regulators have increased restrictions on PFAS due to concerns regarding their persistence and potential environmental impact.

Environmental Persistence

PFAS degrade extremely slowly and may remain in soil, groundwater, and surface water for extended periods.

Bioaccumulation

Certain PFAS compounds can accumulate in humans and animals over time.

Potential Health Concerns

Scientific studies have examined possible associations between PFAS exposure and various biological effects, leading regulators to adopt precautionary approaches for food contact applications.

Because food packaging may come into direct contact with food products, regulators increasingly require manufacturers to demonstrate that packaging materials comply with PFAS restrictions.

Types of Food Packaging Affected by PFAS Regulations

PFAS restrictions primarily affect food packaging materials that rely on grease-resistant or moisture-resistant barrier technologies.

Paper and Paperboard Packaging

Common examples include:

• Burger wrappers
• Sandwich wraps
• French fry cartons
• Pizza boxes
• Paper plates
• Paper bowls

These products frequently use coatings designed to resist oil and grease penetration.

Molded Fiber Packaging

Examples include:

• Clamshell food containers
• Food trays
• Takeaway packaging

Certain formulations may contain additives intended to improve barrier performance.

Microwave Food Packaging

Examples include:

• Microwave popcorn bags
• Heat-resistant paper packaging
• Ready-meal packaging

These products often require barrier performance under elevated temperatures.

Composite Food Packaging

Examples include:

• Multi-layer packaging
• Laminated paper-plastic structures
• Specialty barrier packaging

PFAS may be present in one or more layers depending on the packaging design.

Global PFAS Regulations for Food Packaging

United States PFAS Regulations

The United States regulates PFAS through a combination of federal and state-level controls.

Key developments include:

• FDA review of PFAS-related Food Contact Notifications (FCNs)
• Withdrawal of many PFAS food contact authorizations
• State-level restrictions on intentionally added PFAS

Several states have introduced specific restrictions affecting food packaging materials, including:

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

Companies supplying food packaging to the U.S. market should evaluate both federal and state requirements.

European Union PFAS Regulations

The European Union regulates PFAS through multiple frameworks, including:

• Regulation (EC) No. 1935/2004
• REACH Regulation
• Packaging and Packaging Waste Regulation (PPWR)

Under the PPWR framework, PFAS restrictions include:

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

These requirements increase the importance of testing and technical documentation for food packaging manufacturers.

Germany

Companies supplying food packaging materials to Germany may also need to demonstrate compliance with applicable food contact material requirements.

Canada

Health Canada evaluates food packaging safety through food contact material assessments and supporting compliance documentation.

Asia-Pacific Markets

PFAS controls vary across Asia-Pacific markets.

Requirements may be addressed through:

• Food contact material regulations
• Chemical management regulations
• Product safety frameworks

Exporters should verify requirements for each destination market individually.

PFAS Testing Requirements for Food Packaging

Laboratory testing is one of the most effective methods for demonstrating compliance with PFAS restrictions.

Total Fluorine (TF) Testing

Total Fluorine testing measures the overall fluorine content within a packaging material.

This method is commonly used as an initial screening tool.

Total Organic Fluorine (TOF) Testing

TOF testing focuses on organic fluorinated compounds and provides additional information regarding the potential presence of PFAS substances.

Targeted PFAS Analysis

Targeted PFAS analysis typically uses LC-MS/MS technology to identify and quantify specific PFAS compounds.

This method is often required when regulations establish limits for individual PFAS substances.

Migration Testing

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

Migration assessments may be required as part of broader food contact material compliance evaluations.

When Is PFAS Testing Required?

PFAS testing may be appropriate when:

• Exporting food packaging to regulated markets
• Introducing new packaging materials
• Changing suppliers or material formulations
• Responding to customer compliance requirements
• Supporting retailer approval programs
• Preparing for compliance audits

Testing provides objective evidence to support compliance claims and reduce regulatory risk.

PFAS Compliance Documentation Requirements

Supporting documentation plays an important role in demonstrating compliance.

Typical documentation may include:

• Declaration of Non-Intentionally Added PFAS
• Laboratory test reports
• Material composition information
• Supplier declarations
• REACH compliance statements
• Food contact compliance declarations

Proper documentation helps support regulatory reviews, customer audits, and supply chain verification activities.

Common PFAS Compliance Failures

Several recurring issues frequently create compliance challenges.

Reliance on Supplier Declarations Alone

Supplier statements may not provide sufficient evidence without supporting laboratory data.

Incorrect Interpretation of Testing Results

Screening results and regulatory limits serve different purposes and should not be interpreted interchangeably.

Outdated Compliance Documentation

Historical compliance records may no longer reflect current regulatory requirements.

Material Changes Without Reassessment

Changes in raw materials, coatings, or suppliers may affect PFAS compliance status.

Failure to Monitor Regulatory Updates

PFAS regulations continue to evolve, making ongoing monitoring essential.

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PFAS restrictions are becoming an increasingly important aspect of food packaging compliance. Companies supplying food packaging materials should establish a structured compliance program that includes supplier management, laboratory testing, regulatory monitoring, and technical documentation. Early evaluation of PFAS content and testing requirements helps reduce compliance risks and supports successful market access across global food packaging supply chains.

Frequently Asked Questions