a series of bottlenecks. Under Article 39, manufacturers and brand owners have to draw up formal EU Declarations of Conformity( DoC) and maintain an extensive file for every single packaging SKU. This has led to a significant change in the way that many companies manage their data and also opened the door to an administrative nightmare in aggregating component-level bills of materials, multi-tier upstream suppliersEtc.
Another complication is the question of who is classified as the‘ producer’ under the PPWR. This has led to major retail chains pushing back against the ruling that the entity whose trademark is on the packaging is the legal producer. As a result, supplementary service contracts are proliferating to keep the retailer’ s name on the DoC, but to shift 100 % of the compliance work onto the food brand supplier.
PFAS testing challenges
One of the most immediate impacts for food and drink producers, however, is the requirement for packaging to demonstrate they are within the new PFAS limits. A bottleneck has been created here due to brand owners having to ensure they have comprehensive lab reports and certified chemical analyses from their suppliers. Combine this with the fact that another consumer product restriction – the Regulation( EU) 2024 / 2462( PFHxA ban)- came into force on 10 Oct 2026, and the strain on chemical analytics departments across the EU has been compounded.
An added complication is that total fluorine( TF) tests tell the producer how much fluorine is in the packaging but not which PFAS, whether its polymeric( highly stable) or mobile or whether it can migrate into food. So, a tiny amount of inert fluoropolymer may cause a packaging failure, while a more toxic, mobile PFAS could pass if below detection. Also, the regulatory threshold of 25 ppb per PFAS is at the threshold of quantifiable limits in complex matrices, meaning that two labs could test the same packaging and get different conclusions.
For the time being, TF testing is the measurement of choice for PPWR food contact packaging compliance. So how can producers offer customers‘ PFAS-free’ food contact packaging with confidence? Well, many are embracing a twotier testing strategy of total fluorine screening and targeted PFAS analysis if the TF is elevated, to test for extractable / ionic PFAS and assess migration relevance.
Switching away from PFAS use isn’ t a luxury now but a necessity in food contact packaging aimed at the EU market. However, it requires a strong materials supply chain working together to support the brand owners and packaging designers with all important PFASfree solutions.
Liner innovations supporting PPWR and PFAS-NIA
When it comes to food-contact packaging, every part of the container that touches the product directly must comply with the PPWR’ s strict total fluorine thresholds. And that means paying attention to the material chosen to seal the container. Even before the mandatory ban came into force, Selig’ s R & D team was working closely with material suppliers to transition to PFAS-NIA( notintentionally added) liners.
As a result, Selig was the first liner manufacturer to offer a PFAS not-intentionally added( PFAS- NIA) solution for the majority of our product portfolios. Now, all of Selig’ s induction liner products are PFAS-NIA. In addition, the technical team works closely with customers to ensure that switching to these products is a smooth process within the factory, allowing brand owners to purchase the liners with confidence.
So, with the PPWR keeping food and drink packaging producers and testing labs busy across Europe and beyond, how are you approaching the new regulations and PFAS-Free compliance? For more information on how to make sure your container sealing supports compliance why not give the technical team at Selig a call. Change is coming, so are you ready?
www. seliggroup. com
FDPP- www. fdpp. co. uk 23