PFAS Regulation: Ambition Meets Reality
From August 12, 2026, new limit values for PFAS in food packaging will apply:
- 25 ppb for individual substances
- 250 ppb for the sum
- 50 ppm for total PFAS
These requirements are ambitious – and pose practical challenges for many companies.
Dr. Ernst Simon (Flexible Packaging Europe) assesses the situation in the InnoTalk as follows:
“The PFAS regulation for food packaging in the PPWR is a knee-jerk reaction.”
His criticism is mainly directed at the implementation speed. Parallel to the PPWR, a comprehensive PFAS restriction is underway within the REACH framework, which is significantly broader in scope and being developed on a longer-term basis. The PPWR, on the other hand, intervenes in a specific market area in the short term.
The central problem:
- Harmonized test methods are lacking
- Guidelines are inconsistent and in flux
- Testing capacities are limited
This leaves companies facing a challenging situation: clear limit values – but no clearly standardized testing practice.
Analytics in Reality Check: What is Already Possible and Necessary Today
While Ernst Simon describes the regulatory tensions, Dr. Tim Schlüter (Innoform Testservice) shows how the industry can deal with this situation in practical terms.
His key message:
“The biggest problem is: there are no harmonized analytical methods.”
Total Fluorine as a Pragmatic Entry Point
In practice, the assessment often begins with the total fluorine content (TF). This serves as a screening to quickly identify critical materials.
If the total fluorine content is below a certain threshold value, the material can initially be classified as non-critical. If it is higher, more detailed investigations are required.
The advantage of this approach:
- quick orientation
- broad applicability
The disadvantage:
A low total value does not automatically mean that the strict ppb limits are met.
Differentiation: Organic vs. Inorganic Fluorine
To be more precise, analytics distinguish between:
- inorganic fluorine (e.g., from minerals)
- organic fluorine (incl. PFAS)
The PFAS-relevant portion is estimated via the organic fluorine content. This results from the difference between total fluorine and inorganic fluorine.
However, the procedure is demanding:
- Results depend heavily on measurement conditions
- Reproducibility is critical
Limitations of Currently Discussed Methods
The analytical methods proposed in the guideline are not unreservedly suitable from Tim Schlüter’s perspective.
Figure 4: Limitations of the Methodology
In particular:
- Pyrolysis-GC/MS can deliver incomplete results
- TOP assays are not fully compatible with the logic of the PPWR
This creates a realistic picture:
Analytics today provide valuable insights – but no conclusive certainty.
Practical Question from the InnoTalk
A frequently asked audience question was:
“Do I have to test if I don’t intentionally use PFAS?”
Ernst Simon’s answer is clear:
- What matters is the content in the material, not the intention
- Even unintentional entries from raw materials or processes are relevant
“Not intentionally added” does not replace testing.
What Companies Should Do Now
Despite unclear framework conditions, clear action steps can be derived:
1. Systematically Assess Risks
- Where do potential PFAS entries occur?
- Which materials are critical?
2. Involve Supply Chains
- Actively request information on PFAS
- Document transparency
3. Establish Screening
- Start with total fluorine
- Gradually deepen in case of anomalies
4. Prioritize Instead of Over-analyzing
- Focus on known risk areas
- Pragmatic approach instead of full testing
Conclusion
PFAS regulation brings the industry into a transition phase:
clear goals – but still unclear paths to get there.
However, the contributions from Ernst Simon and Tim Schlüter show:
- The challenges are understood
- Practical approaches are available
- A structured approach is possible
Don’t wait for perfect solutions – actively manage uncertainty and act systematically.