# The EU PFAS limit for food-contact paper and board is as much a paperwork test as a chemistry test, and the name on the pack signs for it

> Since 12 August 2026, food-contact packaging may not be placed on the EU market with PFAS at or above 25 ppb for any single PFAS, 250 ppb for their sum or 50 ppm for total PFAS, and for paper and board the practical question is whether each grade carries a fluorine result and a supplier statement that the brand owner can put behind its declaration of conformity.

Publisher: Strategic Packaging Insights  
Published: 2026-11-01  
Last updated: 2026-11-01  
Page: https://www.strategicpackaginginsights.com/insights/pfas-food-contact-packaging-limits-paper-board/

**Since 12 August 2026, food-contact packaging may not be placed on the EU market with PFAS at or above 25 ppb for any single PFAS, 250 ppb for their sum or 50 ppm for total PFAS, and for paper and board the practical question is whether each grade carries a fluorine result and a supplier statement that the brand owner can put behind its declaration of conformity.**

Article 5(5) of Regulation (EU) 2025/40 sets the limits, and the Commission's June 2026 guidance, Notice C/2026/3084, supplies the only EU reference for how to test against them. Strategic Packaging Insights (SPI) read both against Denmark's six years of enforcing a stricter paper and board ban, and the gap that matters is less the numbers than who holds which document.

## Executive summary

Article 5(5) of the Packaging and Packaging Waste Regulation (PPWR) is the one substance rule in the regulation that already bites with a fixed number. From 12 August 2026, food-contact packaging may not be placed on the market if it contains per- and polyfluoroalkyl substances (PFAS) at or above 25 ppb for any PFAS by targeted analysis, 250 ppb for the sum of targeted PFAS, or 50 ppm for PFAS including polymeric PFAS (Commission Notice C/2026/3084, 10 June 2026). The rule is framed by concentration, not by material, but paper and board carry most of the exposure because fluorinated treatments were long used to give fibre its grease and water resistance (SPI rule note [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/)).

The guidance gives the market a working method. There is no harmonised EU test, so the Commission sets out three steps: total fluorine first, with results below 50 mg/kg treated as compliant; then pyrolysis-GC/MS to tell organic from inorganic fluorine; then direct total oxidisable precursor (TOP) analysis against the 25 and 250 microgram per kg limits (Exhibit 3).

The harder part is the file behind each pack. The PPWR names the manufacturer, the operator whose name or trademark is on the packaging, as the party that runs the conformity assessment and signs the EU declaration of conformity (C/2026/3084, section 2). A brand owner that buys printed cartons from a converter is usually that manufacturer. The converter is a supplier that must hand over the information the brand owner needs, and, where total fluorine exceeds 50 mg/kg, proof of how much of it is PFAS (Exhibit 6).

Denmark shows what enforcement looks like. Its national ban on PFAS in paper and board food-contact materials has applied since 1 July 2020, with an indicator of 20 micrograms of organic fluorine per gram. In a 2024 campaign, 12 of 51 samples were above that indicator but only 2 were above 50, and 9 of 48 companies inspected could not document PFAS compliance (Fødevarestyrelsen, 8 May 2025).

For leaders, the moves are practical: map every food-contact grade to a fluorine result, tie supplier statements to grade and lot, date stock by filling or customs release, and plan for the Commission's review of the restriction, which the Commission timeline dates to 12 February 2030.

## Key findings

1. Article 5(5) has applied to food-contact packaging since 12 August 2026, 79 days before this piece, with limits of 25 ppb, 250 ppb and 50 ppm and no period to sell off stock placed after that date (C/2026/3084).
2. The three limits differ by a factor of 2,000: 25 mg of a single PFAS per tonne of packaging against 50 g of total PFAS per tonne (SPI calculation from the published limits, Exhibit 1).
3. The Commission treats any sample with total fluorine below 50 mg/kg as compliant and states that, on the evidence it holds, every sample that passes that first step also passes the other two (C/2026/3084, section 5).
4. There is no exemption for recycled material, which matters for recycled fibre: Denmark's authority names recycled paper and board and printing inks as possible sources of raised fluorine results (Fødevarestyrelsen, 2025).
5. In Denmark's 2024 campaign, 12 of 51 paper and board samples (23.5%) were above the 20 mg/kg organic fluorine indicator, and 2 (3.9%) were above 50 mg/kg, the EU screening value (SPI calculation from the campaign report, Exhibit 7).
6. **SPI analysis:**  for a filled carton the manufacturer under the PPWR is usually the brand owner, so the declaration of conformity sits with the brand and the converter's duty is to supply evidence; for empty service packaging such as paper cups, the moment of placing on the market is delivery, so the converter's or distributor's own sale can be the trigger (Exhibits 4 and 5).
7. The review date is not settled in the sources: the Commission timeline lists a review of the Article 5(5) restriction by 12 February 2030, while the German text reproduced by LX Gesetze reads 12 August 2030; SPI has not yet confirmed either against the Official Journal.

## What Article 5(5) says, and what it leaves open

The Commission's guidance quotes Article 5(5) in full in its section 5, and that quotation is the basis for the limits used here. Food-contact packaging shall not be placed on the market from 12 August 2026 if it contains PFAS in a concentration equal to or above the three values in Exhibit 1 (C/2026/3084). Limit (c) carries a duty of its own: if total fluorine exceeds 50 mg/kg, the economic operator concerned must, on request, provide proof of the quantity of fluorine measured as PFAS or non-PFAS, so that the technical documentation under Annex VII can be drawn up.

The paragraph sits in Article 5 on substances in packaging. Article 5(1) requires all packaging to be made so that substances of concern are kept to a minimum, Article 5(2) asks the Commission for a report on substances of concern by 31 December 2026, and Article 5(4) caps the sum of lead, cadmium, mercury and hexavalent chromium (German text reproduced by LX Gesetze; Commission timeline). Only Article 5(5) singles out a chemical family for one use, food contact.

Recital 21 gives the reason. It treats exposure to PFAS through food-contact packaging as a risk that is not adequately controlled, given the non-threshold nature of the hazards, and asks the Commission to evaluate whether the restriction should be amended or repealed so that it does not duplicate other Union acts (Regulation (EU) 2025/40, recital 21, SPI rule note [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/)). Recital 24 recalls that substance restrictions belong mainly to REACH, Regulation (EC) No 1907/2006, and that food-contact materials are also governed by Regulation (EC) No 1935/2004.

Three points stay open in the official sources SPI read. First, the definition of PFAS: the German text reproduced by LX Gesetze defines PFAS as substances with at least one fully fluorinated methyl or methylene carbon atom without any hydrogen, chlorine, bromine or iodine attached, with listed exceptions; SPI has not yet confirmed that wording against the Official Journal. Second, Article 5(6): the same text says compliance with paragraphs 4 and 5 is to be shown in the technical documentation under Annex VII, which SPI has also not yet confirmed against the Official Journal. Third, the review date, discussed under What to watch.

The tracker holds the rule as [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/), with the parent regulation as [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/). The general PPWR picture since 12 August 2026 is in SPI's [PPWR after August 2026](https://www.strategicpackaginginsights.com/insights/ppwr-after-august-2026/) piece, which this article does not repeat.

## Why paper and board carry most of the exposure

The rule names no material, yet the SPI rule note for [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/) points first to papers, boards, moulded fibre, coatings and inks that used fluorinated chemistry for grease and water resistance. Plastic, glass and metal food packaging rarely needed that treatment. Fibre that holds burgers, pastries, pizza or popcorn often did.

The Danish campaign gives the product list a buyer should start from. Its 51 samples, taken from 1 May to 30 June 2024 at 48 companies, covered burger paper, popcorn cups, straws, pizza trays, coffee filters, sandwich paper, air fryer moulds, paper boxes, muffin moulds, paper cups and plates, bagasse trays, baking paper, kitchen roll, napkins, wrapping paper, paper bags and cheese paper (Fødevarestyrelsen, 8 May 2025). The 12 results above the indicator came from delis, pizza trays, straws, muffin moulds, bowls, wrapping paper and a sandwich bag (Exhibit 7).

Two features of fibre make the EU test harder to pass with confidence than the absence of an intentional treatment suggests. One is recycled content. The Commission states that there are no exceptions for packaging containing recycled material (C/2026/3084), and Denmark's authority lists recycled paper and board and printing inks as possible sources of raised readings. The other is the environment: McDonald's, which reports on this, says fluorinated compounds in the local environment make it hard to rule out traces of organic fluorine in packaging (McDonald's, Goal Performance and Reporting).

SPI analysis

A grade that has never been treated can still fail a fluorine screen, and a grade that passes today can drift as recovered fibre changes. That is why the evidence for paper and board has to be tied to lot, not only to grade, and why the cost question in SPI's [paper and board fee piece](https://www.strategicpackaginginsights.com/insights/paper-board-epr-fees-euro-schemes/) is separate from this one: EPR schemes charge the same paper line whatever the barrier chemistry, while Article 5(5) can take a grade off the market.

## The test sequence the Commission recommends

The Commission is explicit that no harmonised EU method exists. Its guidance therefore sets out a sequence, to be used from 12 August 2026, that suppliers, brand owners and inspectors can all read in the same way (Exhibit 3).

The sequence matters commercially because it decides how often a grade goes past the first step. The Commission says that, on the evidence currently available to it, all samples compliant with test (1) are also compliant with tests (2) and (3). For a paper mill or converter, a clean total fluorine result is therefore the core document; second and third step results are the exception file.

The guidance adds one limit on the sequence. It applies without prejudice to official controls on materials and articles intended to come into contact with food under Regulation (EU) 2017/625 (C/2026/3084). A food inspector working under food-contact law, rather than a packaging market surveillance authority, may therefore ask other questions about the same item.

Total fluorine counts both organic and inorganic fluorine, so a grade with mineral fillers or pigments that contain fluorine can screen above 50 mg/kg without any PFAS. Step 2 exists for that case. **SPI analysis:**  the 50 mg/kg screen is the same number as limit (c), but it measures fluorine, not PFAS mass, so a result above it is a reason to test further and to ask the supplier for the proof Article 5(5)(c) requires, not evidence of a breach.

## When a pack is caught: placing on the market

Article 5(5) bites at placing on the market, defined in Article 3(1), point (10), as the first making available of packaging, empty or with a product, on the Union market (C/2026/3084). The guidance turns that definition into four practical tests, and they place the trigger at different points in a paper and board supply chain (Exhibit 4).

The stock rule follows from the same definition. Packaging placed on the market before 12 August 2026 may remain on the market and does not need to be withdrawn, but there is no transitional period for selling off stock placed after that date (C/2026/3084). The guidance also notes, citing the Blue Guide, that a manufacturer can place packaging on the market by a mere transfer of legal possession.

SPI analysis

For service packaging the date that counts is the date the converter or wholesaler supplies the empty cup or box, not the date the café fills it. A wholesaler holding a pre-August stock of fluorinated pizza boxes can keep selling those already placed on the market, but a converter cannot clear a run made and first supplied in September. The dated records in Exhibit 6, filling records for filled packs and customs release papers for imports, are what let a business prove which side of the line a lot falls on.

## Who is the manufacturer of a paper pack

The question that decides who signs the declaration of conformity is not who makes the board. The PPWR defines the manufacturer, in Article 3(1), point (13), as a natural or legal person that has packaging or a packaged product designed or manufactured under its own name or trademark, and the Commission adds that this is not necessarily the person that physically produces the packaging (C/2026/3084, sections 2 and 5).

The Commission is equally clear on the consequences. The conformity assessment procedure under Article 38 can be carried out by the manufacturer or by someone else on its behalf, but the EU declaration of conformity under Article 39 must be drafted by the manufacturer, which is the sole economic operator bearing legal responsibility (C/2026/3084, section 2). Exhibit 5 maps that onto a typical paper and board chain.

SPI analysis

For many converters the most important change on 12 August 2026 was not a new limit but a new customer request. A brand owner that must sign for Articles 5 to 12 cannot do so without data on the board, the barrier and the ink, and Article 16 makes that data a legal duty of the supplier rather than a courtesy.

## What converters and brand owners must document

The documentation duties come from five provisions. SPI read the Commission's guidance in English and Articles 15, 16, 38 and 39 in the German text reproduced by LX Gesetze, which is not the official text; points taken only from that text are marked in Exhibit 6.

Three practical consequences follow for paper and board. The first is scope. The declaration covers Articles 5 to 12, so the same signature that covers PFAS will later cover recyclability and recycled content. For recyclability the Commission says manufacturers need not run the conformity assessment until the delegated acts under Article 6(4) enter into force (C/2026/3084, section 6); for PFAS no such delay exists, because Article 5(5) already applies.

The second is the lot. The single-use retention period is five years, so by SPI's calculation a declaration for a lot placed on the market on 12 August 2026 must be held until at least 12 August 2031. A batch number on the pack, or in accompanying documents for items too small to mark, links that file to the item an inspector picks up.

The third is the language of the evidence. A total fluorine result names a method, a laboratory and a sample. The Commission's step 1 threshold gives that result its meaning, but SPI makes no claim about any method or laboratory, and the guidance itself is a recommended approach. Food-contact law adds its own documents: in Denmark, every food-contact material sold wholesale, including paper and board, must already carry a declaration of conformity with Regulation (EC) No 1935/2004 and the national order (Fødevarestyrelsen, August 2024). **SPI analysis:**  businesses that already hold a food-contact declaration under Regulation 1935/2004 have a template, but the PPWR declaration follows its own Annex VIII model and is signed by the manufacturer as the PPWR defines it, which may be a different company.

## Denmark: six years of a stricter paper and board ban

Denmark is the only EU market SPI has found with a national PFAS ban for paper and board food-contact materials and a published enforcement record. Since 1 July 2020 it has been banned to market such materials where PFAS has been added, under Danish executive order 681/2020 on food-contact materials alongside Regulation (EC) No 1935/2004. The indicator value is 20 micrograms of organic fluorine per gram of paper, or 10 micrograms per square decimetre for paper weighing 0.5 g per square decimetre, and content below it is treated as unintended background (Fødevarestyrelsen, August 2024).

The 2024 campaign shows how often real paper and board items cross those lines (Exhibit 7). Of 51 samples, 39 (76%) were below the indicator and 12 (24%) above it. The highest reading, 440 micrograms per gram in a sandwich bag, was 22 times the indicator and, by SPI's calculation, 8.8 times the EU's 50 mg/kg screening value. The other 11 ran from 22 to 51.

The enforcement findings matter as much as the chemistry. Inspectors made 48 control visits between 1 October and 31 December 2024, 45 at wholesalers and 3 at retailers. Nine of 48 companies (19%) were unaware of the rules and could not document PFAS compliance; wholesalers received 4 reprimands and 12 minor findings; two retailers held food-contact documents but nothing on PFAS, and one held none (Fødevarestyrelsen, 8 May 2025). The report compares a 2021 pilot in which 8 of 28 samples were above the indicator, with readings of 26 to 610, and says compliance has improved.

In practice: Fødevarestyrelsen, the Danish Veterinary and Food Administration.

Where analysis finds PFAS, the authority's starting position is to require a functional barrier that prevents migration to the food, and businesses must make sure that the barrier suits the type of food, the contact time and the temperature (Fødevarestyrelsen, August 2024 and 8 May 2025). The authority took samples for chemical analysis and checked documentation at wholesale level, the same two levers an EU market surveillance authority holds under Article 5(5).

Denmark and the EU measure different things, and the comparison should not be reduced to which number is lower (Exhibit 8). Denmark tests for added PFAS with an organic fluorine indicator; the EU sets concentration limits on PFAS themselves, with a total fluorine screen as the Commission's first step. SPI has not yet confirmed whether Denmark will amend executive order 681/2020 now that Article 5(5) applies.

The Oregon contrast, from tracker rule [PR-US-013](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-013/), is about the evidence, not the market. A declaration that no PFAS was intentionally added is the natural proof under Oregon's rule but does not answer a concentration limit in the EU, and an EU fluorine result does not by itself answer a question about intent (SPI rule note [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/)). SPI's [West Coast food service ware piece](https://www.strategicpackaginginsights.com/insights/eps-food-service-ware-california-washington-oregon/) covers Oregon and Washington in detail.

## A grade map for paper and board

SPI groups food-contact paper and board grades on two questions the sources make decisive: whether the grade has a history of fluorinated treatment, and whether its fibre or inks bring in material the producer does not control (Exhibit 9). The first question comes from the SPI rule note's focus on fluorinated barriers; the second from the Commission's statement that recycled material has no exception and the Danish authority's naming of recycled fibre and inks.

The grid tells a buyer where the work concentrates. Group A should need little more than a current total fluorine result and a supplier statement. Group D carries the most evidence, because the producer controls neither the history of the grade nor the inputs of each lot. In Denmark's 2024 results, the items above the indicator included moulded and boxed formats, straws and wrapping papers, which span all four groups depending on how they were made.

Replacing a fluorinated barrier is also a recyclability decision. The SPI rule note for [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/) points to the design-for-recycling criteria in [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/), due on the later of 1 January 2030 and two years after the delegated acts: a plastic or wax barrier that solves a PFAS problem can create a recyclability one. **SPI analysis:**  groups C and D are where the PFAS file and the 2030 recyclability file meet, so the same barrier change should be documented once for both.

## Scenarios: how many grades go past the first step

There is no EU-wide data on how many food-contact paper grades screen above 50 mg/kg. The Danish campaign is the only official sample set SPI found, so Exhibit 10 applies its 2024 distribution to a hypothetical portfolio of 100 food-contact paper and board grades, at three screening cut-offs.

The spread is the point. A buyer that applies the Commission's screen and nothing else would, on the Danish distribution, escalate about 4 grades in 100. A buyer that sets a tighter internal trigger to leave headroom for lot variation would escalate four to six times as many, by SPI's calculation. Both are lawful choices; the second costs more in testing and supplier time but leaves fewer surprises when an inspector samples a later lot.

The low case is a floor for a second reason. Denmark reported organic fluorine, and total fluorine adds any inorganic fluorine, so a grade below 50 mg/kg organic fluorine could still screen above 50 mg/kg total fluorine. The Commission's step 2 is designed to clear such grades, but the time it takes belongs in the planning.

## In practice: what three brand owners disclose

The SPI Packaging Buyers Database maps food-contact formats to [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/) for several brand owners. The cases below use only what each company or profile states.

In practice: McDonald's.

McDonald's reports that at the end of 2024, 99.82% of guest packaging items did not contain intentionally added fluorinated compounds, against a goal of all primary guest packaging by the end of 2025. The goal excludes Israel, Latin America and Turkey, Happy Meal book and toy packaging, and primary fibre packaging for food packaged off-site, tray liners, test items and limited local items (McDonald's, Goal Performance and Reporting). The SPI profile records 96% of its European primary guest packaging as fibre-based at year-end 2024. A target framed on intentional addition is the Oregon test in Exhibit 8; the EU test is a measured concentration, so the excluded categories and environmental traces are where an EU file needs results rather than declarations. SPI's [quick-service restaurant piece](https://www.strategicpackaginginsights.com/insights/quick-service-restaurant-packaging-mcdonalds-reuse-rules/) covers the company's wider packaging goals.

In practice: General Mills.

The SPI profile records Cereal Partners France and plants at Arras and Labatut putting product on the French market, with [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/) limiting PFAS in food-contact paper and board for cereal and ice cream from 12 August 2026 (SPI Packaging Buyers Database, General Mills profile). Cereal cartons usually sit in group A or B of Exhibit 9; ice cream cups and lids are more often coated board, where the barrier history decides the group.

In practice: Nestlé.

The SPI profile places NESCAFÉ paper soft packs and KitKat wrappers under [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/) and the [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/) limits from 12 August 2026, through Nestlé's entities in Germany, France, Ireland and Austria (SPI Packaging Buyers Database, Nestlé profile). Paper-based flexible packs combine fibre, a barrier and inks in one item, which is the case Article 16 was written for: the brand owner signs, but only the paper, barrier and ink suppliers hold the data.

## Industry reaction

> "Several protocols and methodologies to test the presence of PFAS in different matrices exist, but there is no harmonised methodology for PFAS in food contact packaging at EU level."

***European Commission** , guidance on Regulation (EU) 2025/40, [Commission Notice C/2026/3084, section 5](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), 10 June 2026*

The same section names total fluorine, pyrolysis-GC/MS and TOP analysis as the stepwise approach, and it names the national market surveillance authorities as the ones competent to check the limits.

> "There are no exceptions regarding packaging containing recycled material."

***European Commission** , guidance on Regulation (EU) 2025/40, [Commission Notice C/2026/3084, section 5](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), 10 June 2026*

For recycled board, that sentence moves the burden onto lot data, because the producer of a recycled grade does not choose every fibre that goes into it.

> "Indikatorværdien er 20 mikrogram organisk fluor per gram papir."
>
>
>
> **Fødevarestyrelsen** , Danish Veterinary and Food Administration, [fact sheet on fluorinated substances in paper and board food-contact materials](https://foedevarestyrelsen.dk/Media/638600156051413124/Faktaark%20fluorerede%20stoffer.pdf), August 2024
>
>
>
> "I Danmark skal alle typer af FKM der markedsføres engros, herunder også dem af papir og pap, ledsages af en overensstemmelseserklæring, som dokumenterer, at produktet overholder kravene i EU-lovgivningen (forordning 1935/2004) og den danske bekendtgørelse 681/2020 om fødevarekontaktmaterialer."

***Fødevarestyrelsen** , Danish Veterinary and Food Administration, [fact sheet on fluorinated substances in paper and board food-contact materials](https://foedevarestyrelsen.dk/Media/638600156051413124/Faktaark%20fluorerede%20stoffer.pdf), August 2024*

In English, the first sentence sets the indicator at 20 micrograms of organic fluorine per gram of paper, and the second says that in Denmark every food-contact material sold wholesale, paper and board included, must come with a declaration of conformity showing it meets Regulation (EC) No 1935/2004 and executive order 681/2020. The Danish campaign found that 19% of companies inspected could not document PFAS compliance, which is the gap the PPWR declaration now asks every manufacturer in the EU to close.

## The gaps in this reading

**Official text.**  The articles of Regulation (EU) 2025/40 were read in the German text reproduced by LX Gesetze, not in the Official Journal. Article 5(5) itself is quoted in full in the Commission's guidance, so the limits are confirmed; the PFAS definition, Article 5(6), the review date and the article-level duties in Articles 15, 16, 38 and 39 are not yet confirmed by SPI against the Official Journal.

**Penalties.**  Sanctions are set in national law. SPI has not yet confirmed the PPWR article on penalties against the official text, and no Article 5(5) case had been published by the Commission as of 30 October 2026 in the sources SPI read.

**Labels.**  PFAS status is not shown on the pack. The harmonised sorting label in [PR-EU-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-003/), from 12 August 2028 at the earliest, concerns material composition, while recital 70 of the regulation points to digital marking of substances of concern, which SPI's [labelling piece](https://www.strategicpackaginginsights.com/insights/ppwr-labelling-harmonised-material-label-digital-marking/) covers.

## What leaders should do now

1. **Heads of quality at converters and mills, by 31 December 2026:**  list every food-contact grade supplied since 12 August 2026 with its first placing date, place it in a group from Exhibit 9, and attach a current total fluorine result to each grade.
2. **Brand owners' regulatory teams, by 31 December 2026:**  confirm for each pack who the manufacturer is under Article 3(1), point (13), and make sure the EU declaration of conformity names Article 5(5) and is backed by the technical documentation the supplier data supports.
3. **Procurement, at the next contract renewal:**  write the Article 16 supplier duty into contracts for board, barriers and inks, including Article 5(5)(c) proof of PFAS or non-PFAS fluorine whenever total fluorine exceeds 50 mg/kg.
4. **Operations and customs teams, now:**  keep pre-August stock apart from later stock, using filling records for filled packs, first-supply dates for empty service packaging and customs release papers for imports (Exhibit 4).
5. **Packaging development teams, before the 2027 range reviews:**  document every barrier change in groups C and D once for both Article 5(5) and the 2030 recyclability criteria in [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/).
6. **Food service buyers selling into Denmark and Oregon, now:**  keep the Danish organic fluorine evidence and the Oregon no-intentional-addition declarations alongside the EU file, since none of the three proves the other two (Exhibit 8).
7. **Compliance owners, by 31 December 2026:**  set a watch on the Commission's Article 5(2) substances report and on the review date of Article 5(5), with an owner who will check the Official Journal text.

## Questions for your board

- Do we know who signs the PPWR declaration of conformity for each of our food-contact packs, and is it us?
- What share of our food-contact paper and board grades has a total fluorine result dated after 12 August 2026?
- How many of our grades use recycled fibre or third-party inks, and are they tested per lot?
- Can we prove which of our stock was placed on the market before 12 August 2026?
- Which barrier changes made to remove fluorinated chemistry could fail the 2030 recyclability test?
- If a Danish-style inspection asked our wholesalers for PFAS documents tomorrow, how many could produce them?

## What to watch

- **31 Dec 2026:**  the Commission's report on substances of concern in packaging is due under Article 5(2), with follow-up that can include REACH restrictions or design-for-recycling criteria (Commission timeline; German text of Article 5).
- **1 Jan 2030:**  the earliest date for design-for-recycling criteria under [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/), which will test the barriers that replaced fluorinated treatments.
- **12 Feb 2030:**  the Commission timeline's date for the review of the Article 5(5) PFAS restriction ([PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/)).
- **12 Aug 2030:**  the evaluation date for Article 5(5) in the German text SPI read; SPI has not yet confirmed which date the Official Journal gives.
- **12 Aug 2031:**  by SPI's calculation, the end of the five-year retention period for declarations covering single-use packaging placed on the market on 12 August 2026.
- **12 Aug 2033:**  the Commission's evaluation of hazardous substances in packaging under Article 5(9), in the German text SPI read; SPI has not yet confirmed it against the Official Journal.

## Methodology

- **Data used:**  SPI tracker rule notes [PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/), [PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/), [PR-EU-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-003/), [PR-EU-010](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-010/) and [PR-US-013](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-013/); SPI Packaging Buyers Database profiles for Danone, General Mills, Kraft Heinz, McDonald's, Mondelez and Nestlé; Commission Notice C/2026/3084, sections 2, 5 and 6; the Commission's PPWR implementation timeline; recitals 21 and 24 of Regulation (EU) 2025/40; Articles 5, 15, 16, 38 and 39 in the German text reproduced by LX Gesetze; Fødevarestyrelsen's August 2024 fact sheet and 8 May 2025 campaign report; McDonald's reporting page.
- **Counting rules:**  limits as quoted in the Commission's guidance; 1 ppb = 1 microgram per kg and 1 ppm = 1 mg per kg, per the guidance's footnotes; per-tonne figures multiply by 1,000; Danish shares divide by the 51 samples reported; no currency is compared.
- **Framework and scenarios:**  the grade groups in Exhibit 9 and the 25 mg/kg base case in Exhibit 10 are SPI assumptions. The scenario treats organic fluorine as a floor for total fluorine and applies one country's 2024 sample to a hypothetical portfolio.
- **Cut-off:**  30 October 2026.
- **Limitations:**  the articles of the regulation are read in an unofficial German reproduction except where the Commission quotes them; points not confirmed against the Official Journal are marked. SPI makes no testing, certification or compliance claim for any product or company. This is business analysis, not legal advice; check with counsel for a specific pack or flow.

**Related:**  [Huhtamaki Q3 2026 results](https://www.strategicpackaginginsights.com/news/huhtamaki-q3-2026-results/)

## Sources

1. European Commission, Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste (OJ C, 10.6.2026), sections 2, 5 and 6, [https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084](https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52026XC03084), consulted 2026-10-30.
2. EUR-Lex, Regulation (EU) 2025/40, OJ L 22.1.2025, recitals 21, 24 and 70, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:L_202500040), consulted 2026-10-14.
3. EUR-Lex, Regulation (EU) 2025/40, ELI record and document metadata, [https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng](https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng), consulted 2026-10-30.
4. European Commission Green Forum, PPWR implementation timeline of implementing and delegated acts, [https://green-forum.ec.europa.eu/packaging-and-packaging-waste-regulation-implementation_en](https://green-forum.ec.europa.eu/packaging-and-packaging-waste-regulation-implementation_en), consulted 2026-10-30.
5. European Parliament Legislative Observatory, Regulation (EU) 2025/40 summary, [https://oeil.europarl.europa.eu/oeil/en/document-summary?id=1802233](https://oeil.europarl.europa.eu/oeil/en/document-summary?id=1802233), consulted 2026-10-14.
6. European Parliament Legislative Observatory, procedure file 2022/0396(COD), [https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2022/0396(COD](https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2022/0396(COD)), consulted 2026-10-14.
7. Fødevarestyrelsen, Faktaark: fluorerede stoffer i fødevarekontaktmaterialer af papir og pap (August 2024), [https://foedevarestyrelsen.dk/Media/638600156051413124/Faktaark%20fluorerede%20stoffer.pdf](https://foedevarestyrelsen.dk/Media/638600156051413124/Faktaark%20fluorerede%20stoffer.pdf), consulted 2026-10-30.
8. Fødevarestyrelsen, Slutrapport for kampagnen PFAS i fødevarekontaktmaterialer af pap og papir, version 4.0 (8 May 2025), [https://foedevarestyrelsen.dk/Media/639171157986553628/PFAS_2024_slutrapport.pdf](https://foedevarestyrelsen.dk/Media/639171157986553628/PFAS_2024_slutrapport.pdf), consulted 2026-10-30.
9. Oregon Department of Environmental Quality, Foodware Containers and Polystyrene Foam, [https://www.oregon.gov/deq/mm/production/pages/polystyrene.aspx](https://www.oregon.gov/deq/mm/production/pages/polystyrene.aspx), consulted 2026-10-14.
10. Oregon Legislative Policy and Research Office, Senate Bill 543 fact sheet (29 August 2024), [https://www.oregonlegislature.gov/committees/2023I1-SEE/WorkgroupDocuments/Senate%20Bill%20543%20Fact%20Sheet.pdf](https://www.oregonlegislature.gov/committees/2023I1-SEE/WorkgroupDocuments/Senate%20Bill%20543%20Fact%20Sheet.pdf), consulted 2026-10-14.
11. LX Gesetze, Artikel 5 PPWR, German text as reproduced (unofficial), [https://lxgesetze.de/ppwr/5](https://lxgesetze.de/ppwr/5), consulted 2026-10-30.
12. LX Gesetze, Artikel 15 PPWR, Pflichten der Erzeuger (unofficial), [https://lxgesetze.de/ppwr/15](https://lxgesetze.de/ppwr/15), consulted 2026-10-30.
13. LX Gesetze, Artikel 16 PPWR, Pflichten der Lieferanten (unofficial), [https://lxgesetze.de/ppwr/16](https://lxgesetze.de/ppwr/16), consulted 2026-10-30.
14. LX Gesetze, Artikel 38 PPWR, Konformitätsbewertungsverfahren (unofficial), [https://lxgesetze.de/ppwr/38](https://lxgesetze.de/ppwr/38), consulted 2026-10-30.
15. LX Gesetze, Artikel 39 PPWR, EU-Konformitätserklärung (unofficial), [https://lxgesetze.de/ppwr/39](https://lxgesetze.de/ppwr/39), consulted 2026-10-30.
16. McDonald's, Goal Performance and Reporting, [https://corporate.mcdonalds.com/corpmcd/our-purpose-and-impact/impact-strategy-and-reporting/performance-reports.html](https://corporate.mcdonalds.com/corpmcd/our-purpose-and-impact/impact-strategy-and-reporting/performance-reports.html), consulted 2026-10-30.
17. SPI Packaging Buyers Database, Danone, General Mills, Kraft Heinz, McDonald's, Mondelez and Nestlé profiles, /data/packaging-buyers-database/, consulted 2026-10-30.
18. SPI Regulation Tracker, rules PR-EU-001, PR-EU-002, PR-EU-003, PR-EU-010 and PR-US-013 and their rule notes, /data/packaging-regulation-tracker/european-union/pr-eu-002/, consulted 2026-10-30.