EU Regulation 2024/3005 (PPWR)
The European Union's Packaging and Packaging Waste Regulation (PPWR), adopted as EU Regulation 2024/3005, introduces the world's most detailed PFAS testing framework for food-contact packaging, effective August 1, 2026. The regulation establishes a three-tier limit system: Tier 1 sets a 25 parts per billion limit for any individual PFAS compound, Tier 2 sets a 250 ppb limit for the sum of listed PFAS compounds, and Tier 3 caps total organic fluorine (TOF) at 50 parts per million. This tiered approach means packaging must pass all three tests simultaneously — a product could comply at the TOF level yet fail at the individual compound tier.
The three-tier system represents a fundamental shift in how PFAS compliance is measured. In the United States, most states use either an "intentionally added" standard or a single TOF threshold (like California's 100 ppm). The EU's approach requires more sophisticated testing because a single TOF measurement is no longer sufficient. Food businesses exporting to EU member states, or EU-based businesses sourcing packaging globally, must ensure their testing protocols cover all three tiers. This typically requires both targeted analysis for individual compounds and broad-spectrum fluorine screening.
Enforcement of PPWR falls to individual EU member states, which must establish penalties that are "effective, proportionate, and dissuasive" under Article 68. Major markets like Germany, France, and the Netherlands are expected to impose significant fines. For US-based food brands selling into Europe, the PPWR creates a compliance obligation that exceeds any single US state law in its testing complexity. The August 2026 effective date includes an 18-month transition period for existing stock, but new packaging entering the EU market after that date must meet all three tiers.
EU Regulation 2024/3005 (PPWR)
All food packaging
EU Packaging and Packaging Waste Regulation (PPWR) introduces a 3-tier limit system for PFAS in food-contact packaging: Tier 1 — 25 ppb individual PFAS, Tier 2 — 250 ppb sum of listed PFAS, Tier 3 — 50 ppm total organic fluorine (TOF).
Penalties determined by individual EU member states. Must be 'effective, proportionate, and dissuasive' per PPWR Art. 68. Expect significant fines in major markets (DE, FR, NL).
Exemptions
European Union's PFAS ban primarily targets manufacturer and distributor in the supply chain. While food service operators are not directly liable, you should request PFAS-free documentation from your packaging suppliers to avoid supply chain disruptions.
Implement Three-Tier PFAS Testing Protocol
The PPWR requires compliance at all three tiers simultaneously: 25 ppb individual PFAS, 250 ppb sum of listed PFAS, and 50 ppm TOF. A single TOF test is not sufficient — you need targeted compound analysis as well.
Work with EU-Accredited Testing Laboratories
Ensure your testing provider is recognized by EU member state authorities and can issue certificates of analysis covering all three PPWR tiers. Testing methodology must align with the regulation's specified analytical standards.
Review Packaging for Individual Compound Hotspots
Even if overall TOF is low, a single PFAS compound above 25 ppb triggers non-compliance. Investigate packaging components, coatings, and adhesives for specific compounds that might exceed the Tier 1 threshold.
Plan for Member State Enforcement Variations
Each EU country will set its own penalty structure and enforcement procedures. If you sell into multiple member states, identify the strictest national implementation and use that as your compliance baseline.
Use our free compliance checker to verify your food packaging meets European Union's PFAS regulations.
Run Free Compliance CheckLegal Disclaimer
This page provides general information about European Union's PFAS food packaging regulations and is not legal advice. Regulations may change; always verify current requirements with the relevant regulatory authority. PFAS Packaging Check is an information tool — consult qualified legal counsel for advice specific to your situation.