In early 2025, a survey revealed that over 90% of molded pulp tableware products in my country had excessively high total fluoride content. Compared to relevant EU standards, these levels far exceeded limits, with some reaching 16.6 times the limit.
The EU officially published the Packaging and Packaging Waste Regulation (EU) 2025/40 on January 22, 2025, which came into effect on February 11, 2025. According to the regulations, this regulation will be fully implemented from August 12, 2026, simultaneously repealing the nearly 30-year-old Directive 94/62/EC. One of the most anticipated provisions is the restriction on per- and polyfluoroalkyl substances (PFAS).
PFAS are a class of fluorinated organic compounds that have long been widely used in food contact materials (such as greaseproof paper and fast food container linings), cosmetics (waterproof mascara and foundation), textiles (outdoor clothing coatings), non-stick cookware, and fire-fighting foam due to their excellent waterproof, oil-proof, and high-temperature resistance properties. However, PFAS are extremely difficult to degrade in the natural environment and can continuously accumulate in the human body and ecosystems. Numerous studies have confirmed their association with endocrine disruption, liver and kidney damage, immunosuppression, and even an increased risk of cancer. For these reasons, the European Union has listed them as "Substances of Concern" (SFCs) with priority control.
According to Article 5 of the EU PFAS PRWR, from August 12, 2026, all packaging materials used for food contact must contain: each PFAS substance must not exceed 25 ppb (parts per billion); the total amount of all PFAS must not exceed 250 ppb; and the total PFAS content, calculated as fluorine, must not exceed 50 ppm (parts per million). Furthermore, if the total fluoride content in the packaging exceeds 50 ppm, manufacturers or importers must provide downstream customers with proof of fluoride content from PFAS or non-PFAS sources to ensure traceability and verifiability.
The EU is not an isolated case; PFAS restrictions are becoming a global trend. In April 2024, the US Food and Drug Administration (FDA) announced that the US would no longer sell food contact oil-resistant materials containing PFAS. Minnesota, Colorado, and other states have already banned the use of PFAS in food packaging. Japan banned 138 perfluorinated compounds starting January 10, 2025. France banned the sale of cosmetics and textiles containing PFAS starting in 2026. China has implemented bans or strict restrictions on typical perfluorinated compounds such as PFOS, PFOA, and PFHxS, but has not comprehensively banned all PFAS.
What risks do Chinese companies face? If PFAS levels are found to exceed limits on packaging, products will be refused entry, recalled, or destroyed. Many companies have yet to identify whether their packaging contains PFAS (such as oleophobic coatings, adhesives, and inks). Environmental compliance has become a core procurement standard for international buyers (such as IKEA, Nestlé, and LVMH).
It is particularly noteworthy that PFAS can be found in seemingly "ordinary" packaging: the oleophobic coating on the inner layer of kraft paper bags; coffee filters and tea bags; frozen food cartons; fast food trays, baking paper, etc. These all fall under the "food contact packaging" explicitly covered by PPWR.
So, how should companies prepare in advance? The key is to require all packaging suppliers to provide PFAS-free declarations, conduct third-party testing on high-risk materials (paper products, composite films, coatings); adopt fluorine-free oleophobic technologies (such as starch-based, chitosan, and PLA coatings); choose compostable packaging certified by OK Compost, TÜV Austria, etc.; and cooperate with organizations such as SGS, TÜV, and CTI to conduct compliance assessments.
The implementation of PPWR is not only an upgrade of environmental regulations but also a signal of restructuring the global consumer goods value chain. Whoever can be the first to achieve a green packaging transformation that is "PFAS-free, recyclable, and reduced in volume" will win access to the EU and even the global high-end market.
August 12, 2026 is fast approaching; now is the best time to act.
