At a glance:

  • EU PPWR Regulation (EU) 2025/40 Article 5 PFAS restriction applies from 12 August 2026 with no stock grandfathering for packaging placed after that date.
  • The legal limit is 50 ppm for all PFAS including polymeric PFAS — not a total-fluorine threshold. Total fluorine via CIC is a first-tier screen only.
  • Pet food and animal feed packaging are OUT of scope of the August 2026 deadline per Commission and industry guidance.
  • Direct human-food-contact FFS film (cereals, rice, sugar, flour, frozen food) is IN scope and must be verified PFAS-free.
  • Three PFAS-free polymer processing aids are now commercially available: Clariant AddWorks PPA, Dow DOWSIL 5-1050, SILIKE SILIMER 9100/9300.
  • Technical documentation, CoAs, and multi-tier supply-chain traceability (PPAs, slip additives, adhesives, inks) shift the burden of proof to the converter.

Prepared by Easier Materials Regulatory Affairs. Reviewed by Easier Materials QA Department.

Introduction

On 11 February 2025, Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation (PPWR) — entered into force, replacing Directive 94/62/EC as directly applicable law across all 27 EU Member States. Its PFAS restriction for food-contact packaging takes effect on 12 August 2026. Packaging placed on the EU market before that date may remain in circulation, but any food-contact packaging placed from 12 August 2026 onward must meet three concentration limits — verified by documented testing.

For FFS packaging film converters and buyers, the deadline is tight and the scope is narrower than many trade headlines imply. This article resolves three buyer questions: (1) what Article 5 actually covers, (2) which FFS film applications are in scope and which are not, and (3) how compliance is verified — including the commonly misstated relationship between "total fluorine" and "total PFAS including polymeric."

What does the EU PPWR Article 5 PFAS restriction actually cover?

Article 5 of Regulation (EU) 2025/40 sets three PFAS thresholds for food-contact packaging, and all three must be met:

  • ≤ 25 ppb for any individual non-polymeric PFAS substance
  • ≤ 250 ppb for the sum of non-polymeric PFAS substances
  • ≤ 50 ppm for all PFAS including polymeric PFAS

The third limit — the 50 ppm cap — is the one most directly relevant to polyolefin FFS film, because the dominant residual PFAS source in film extrusion is the fluoropolymer-based polymer processing aid (PPA) used to eliminate melt fracture. A fluoropolymer PPA is polymeric PFAS. It counts toward the 50 ppm ceiling even if no non-polymeric PFAS is intentionally added elsewhere.

Per Noventiz's legal analysis of Article 5, "marketability depends solely on the verified concentration. No distinction is made as to whether PFAS were intentionally added or unintentionally present." Recycled content is not exempt. The burden of proof sits with the packaging manufacturer, supported by test data and supplier declarations covering every process aid, coating, adhesive, and ink layer in the laminate.

Which FFS film applications are in scope — and which are not?

Scope precision matters, because several of the food-and-feed applications that share a production line with human-food FFS are explicitly outside the August 2026 deadline. Per Amcor's 2026-01-26 regulatory brief, the PPWR PFAS restriction "does not extend to pet food and animal feed packaging, personal care and beauty packaging, healthcare packaging, and other non-food goods." Zidan Packaging's 2026 industry overview corroborates this carve-out.

The practical scope picture for FFS film SKUs:

FFS film end-use Aug 2026 PFAS scope Notes
Human food — direct contact (cereal, rice, sugar, flour, salt, frozen, bakery) In scope 25/250 ppb + 50 ppm apply; technical documentation required
Human food — secondary / transit outer packaging Grey zone Food-contact layer test generally drives decision; verify per EC guidance
Pet food primary packaging Out of scope of Aug 2026 deadline Market pull (brand owners) is pushing voluntary PFAS-free anyway
Animal feed bags Out of scope of Aug 2026 deadline Not a food-contact material under PPWR
Fertilizer, cement, industrial chemical bags Out of scope No food-contact intent
Multilayer FFS with fluorine in adhesive / ink / print layer Grey zone Commission guidance measures packaging as placed on market; composite testing decisive
Recycled-content FFS blended from mixed feedstocks Grey zone No exemption for recycled content; traceability required

The "out of scope" designations above relate strictly to the 12 August 2026 PFAS deadline. Brand owners in the pet-food category (for example, Coveris announced PFAS-free monomaterial pet-food packaging ahead of Interzoo 2026) are pulling the de facto specification toward PFAS-free regardless. Converters selling into human-food FFS and pet food on the same extrusion line should plan for a PFAS-free PPA qualification in both cases — legal obligation on the former, procurement expectation on the latter.

Grey zones deserve explicit technical review. A cereal-box inner liner sold into a human-food customer is in scope; a fertilizer FFS film sold to an agricultural co-op is not. A multilayer structure where the food-contact layer is PFAS-free but an adhesive or ink layer contains fluorine may fail the 50 ppm total-PFAS test on the packaging as placed on market — and the Commission's March 2026 guidance measures the packaging as a whole, not layer-by-layer.

How is the 50 ppm threshold measured, and what must converters verify?

The 50 ppm limit in Article 5 is a total PFAS including polymeric concentration. It is not, in legal terms, a total-fluorine limit. That distinction is important because total fluorine (for example via combustion ion chromatography, CIC) is the operational first-tier screen, not the legal threshold itself.

The European Commission's Communication C(2026) 2151 final (30 March 2026) formalises a stepwise approach:

  • Step 1 — Total-fluorine CIC screen (see EPA Method 1621 for AOF). Below 50 ppm, packaging is deemed compliant with the 50 ppm cap.
  • Step 2 — Pyrolysis GC/MS to differentiate organic vs inorganic fluorine. Organic fluorine below 50 ppm = compliant.
  • Step 3 — Targeted LC-MS/MS + TOP assay for the 25 ppb individual and 250 ppb sum non-polymeric thresholds.

PubMed (2025-01) confirms CIC has the lowest detection limits versus PIGE and INAA. PackagingLaw.com's 2026-04-15 analysis stresses that manufacturers must hold technical documentation — a per-batch CoA plus PFAS-free declarations from every PPA and additive supplier.

Converter verification checklist for any food-contact FFS SKU from August 2026:

  • Total-fluorine CIC result on a composite film sample (not per layer)
  • PFAS-free declarations for every PPA, slip, anti-block, and color concentrate
  • Adhesive and ink declarations for multilayer structures
  • Batch-level traceability linking raw-material lots to finished-roll CoAs
  • EU 10/2011 plastic food-contact compliance (layered on top of Article 5)

What PFAS-free polymer processing aids are commercially available for FFS extrusion?

The main residual-fluorine source in polyolefin FFS is the fluoropolymer PPA used to suppress melt fracture and reduce die build-up. Three PFAS-free PPA product lines are now commercially available and validated for polyolefin extrusion, including 5-layer FFS structures:

Supplier Product Launch Chemistry Food-contact status
Clariant AddWorks PPA 101 FG (EMEA/Americas/SEAP) and PPA 122 G (Greater China/SEAP) 2025-06-05 Non-fluorinated, non-silicone, non-polysiloxane Food-contact suitable per Clariant declaration
Dow DOWSIL 5-1050 PPA 2025-09-23 Silicone additive in PE carrier, supplied as masterbatch Compliant with EU 10/2011 and US FDA 21 CFR 174.5
SILIKE Tech SILIMER 9100 / SILIMER 9300 Commercial 2026 Silicone-based masterbatch Validated in 5-layer polyolefin FFS heavy-duty films

Qualification takes time. A typical PPA swap on a 3- or 5-layer FFS line requires pilot extrusion, melt-fracture and die-build-up verification, hot-tack and seal-strength validation against the customer specification, and then a production-scale CoA run. Converters still running a fluoropolymer PPA in mid-2026 face practical risk on any SKU destined for human-food contact — not because the PPA is banned directly, but because it is the most probable cause of a total-fluorine screen failing the 50 ppm Step 1 check.

If you need to align an existing FFS specification to a PFAS-free PPA before the deadline, request a quote and specify the end-use, target line (Haver & Boecker, STATEC BINDER, CHRONOS, CONCETTI, PAYPER), target thickness (80–230 μm), and seal initiation temperature window. Easier Materials can supply film produced with qualified PFAS-free PPAs for food-contact-compliant SKUs while maintaining existing formulations for out-of-scope pet food, feed, fertilizer, and industrial applications.

Scenarios

Scenario A: A human-food FFS converter shipping into the EU

If you produce FFS film for direct human-food contact (cereal, rice, sugar, flour, frozen, bakery primary packaging) into the EU market, the 12 August 2026 PPWR Article 5 PFAS limits apply directly to your finished film. The 50 ppm threshold is total PFAS including polymeric — fluoropolymer PPA residue is the most likely failure path on a polyolefin line.

Documentation chain matters as much as the chemistry. Expect to hold a CoC from the PPA supplier, issue a CoC at the converter level, and pass an audit trail through to the brand owner. Each food-contact SKU needs a batch-level CoA tied to raw-material lots, plus PFAS-free declarations for slip, anti-block, color concentrate, adhesives, and inks where applicable.

A workable timeline is qualifying a PFAS-free PPA in Q2 2026, running first commercial extrusion in Q3 2026, and building buffer stock of compliant film before July 2026. Stock placed before 12 August 2026 may remain on market; stock placed after must comply.

Procurement action: when ordering, specify Clariant AddWorks PPA 101 FG / 122 G, Dow DOWSIL 5-1050, or SILIKE SILIMER 9100/9300 by name, and require the supplier to confirm the 50 ppm total-PFAS (including polymeric) basis on the CoC.

Scenario B: A pet food or animal feed brand owner

If your packaging is for pet food or animal feed (not direct human-food contact), the 12 August 2026 PPWR PFAS deadline does NOT apply to you as a legal matter. Pet food and animal feed packaging are explicitly outside the Article 5 scope per current Commission and industry guidance.

Commercial reality runs ahead of the regulation. Brand-owner pull is increasingly PFAS-free regardless: private-label EU retailers are tightening private-label PFAS policy independent of the regulation, exports to jurisdictions with broader PFAS scope can be in scope elsewhere, and supply-chain resilience favours a single PFAS-free PPA qualification across both human-food and pet-food SKUs on shared lines.

Voluntary substitution should be documented as voluntary. A converter or brand owner can cite a PFAS-free PPA, attach the supplier CoC, and describe the choice as a procurement preference — without claiming the August 2026 PPWR Article 5 obligation applies to feed or pet-food packaging when it does not.

Procurement action: ask the converter for a PFAS-free PPA option on pet-food SKUs and request the same documentation set used for human-food SKUs, while keeping the legal basis of the spec accurately framed.

Scenario C: A multilayer FFS film with adhesive, ink, or print layers (the grey zone)

If your film is multilayer with fluorinated additives in non-polymer layers (adhesives, inks, primers, anti-block agents), your scope position is unclear under current EC guidance. Communication C(2026) 2151 final formalises the stepwise total-fluorine → py-GC/MS → targeted PFAS testing approach, but does not fully resolve how adhesive, ink, and print layers are treated within the 50 ppm total-PFAS limit on packaging as placed on market.

A risk-managed approach is to test the finished film against the 50 ppm total-PFAS limit using the CIC → py-GC/MS → LC-MS/MS + TOP stepwise protocol on a composite sample, and to assume worst-case interpretation pending further guidance. The Commission measures packaging as placed on market, not layer-by-layer, so a PFAS-free food-contact layer over a fluorine-containing adhesive can still fail the screen.

Procurement action: ask suppliers for a full bill-of-materials PFAS declaration covering every additive — adhesives, primers, inks, slips, anti-blocks — including sub-100 ppm additives, not just the PPA.

Recent developments

  • 2025-02-11 — Regulation (EU) 2025/40 entered into force as PPWR, replacing Directive 94/62/EC across the EU. Source: EUR-Lex.
  • 2025-06-05 — Clariant launched AddWorks PPA. PFAS-free, non-silicone processing aids for polyolefin extrusion, with food-contact suitability. Source: Clariant press release.
  • 2025-09-23 — Dow launched DOWSIL 5-1050 PPA. Silicone-based masterbatch PPA, EU 10/2011 and FDA 21 CFR 174.5 compliant. Source: Dow press release; PlasticsToday 2025.
  • 2026-01 to 2026-04 — SILIKE SILIMER 9100 / 9300 deployed in 5-layer polyolefin FFS heavy-duty packaging films. Source: SILIKE technical bulletin.
  • 2026-03-30 — European Commission published final PPWR implementation guidance (Communication C(2026) 2151 final), formalising the stepwise total-fluorine screen → py-GC/MS → targeted PFAS + TOP testing approach. Source: Packaging Europe; measurlabs.com.
  • 2026-04-09 — CIRS Group regulatory update: packaging placed before 12 August 2026 may remain on the market; no stock transition for packaging placed after. Source: cirs-group.com.
  • 2026-04 — Coveris announced PFAS-free monomaterial pet-food packaging ahead of Interzoo 2026 — notable because pet-food packaging is legally out of Article 5 scope, signalling brand-owner-driven market pull toward PFAS-free regardless. Source: PackagingInsights.

References

Summary

The EU PPWR PFAS restriction on food-contact packaging takes effect 12 August 2026 with no grandfathering. Three thresholds apply — 25 ppb individual non-polymeric, 250 ppb sum non-polymeric, and 50 ppm for all PFAS including polymeric — verified through a stepwise test protocol that uses total-fluorine CIC as a first-tier screen, not as the legal limit itself. Pet food, animal feed, fertilizer, cement, and industrial FFS applications are outside the August 2026 deadline; direct human-food-contact FFS is in scope. Fluoropolymer PPAs are the main residual-fluorine source in polyolefin FFS, and three PFAS-free PPA product lines (Clariant AddWorks PPA, Dow DOWSIL 5-1050, SILIKE SILIMER) are commercially available. Converters should document PPA, additive, adhesive, and ink supply with CoAs and supplier declarations, and qualify a PFAS-free PPA on any SKU destined for human-food contact well before August 2026.

FAQ

Is pet food packaging covered by the August 2026 PFAS deadline?

Per current Commission and industry guidance, no. Amcor's 2026 regulatory overview states the PPWR PFAS deadline "does not extend to pet food and animal feed packaging, personal care and beauty packaging, healthcare packaging, and other non-food goods." Brand owners in pet food are nonetheless adopting PFAS-free specifications voluntarily, so market expectations and legal obligations may diverge. Converters should still plan qualification if they run shared lines with human-food FFS.

Is the 50 ppm a total-fluorine or a total-PFAS limit?

It is a total-PFAS limit, including polymeric PFAS. The Commission's March 2026 guidance uses total fluorine via combustion ion chromatography (CIC) as a first-tier operational screen: if total fluorine is below 50 ppm, the packaging is deemed compliant. Exceed that screen and the converter must differentiate organic vs inorganic fluorine and run targeted PFAS analysis to prove the 50 ppm total-PFAS limit is met.

Are multilayer FFS adhesive and ink layers in scope?

The regulation treats packaging as placed on the market, so the composite structure is what the 50 ppm total-PFAS limit applies to. A food-contact layer that is PFAS-free but sits over a fluorine-containing adhesive or ink layer can still fail the total-fluorine screen. Request PFAS-free declarations from every supplier in the laminate — adhesives, primers, inks, slip additives — not only the PPA supplier.

What happens to FFS film produced before 12 August 2026?

Per CIRS Group's April 2026 summary, packaging placed on the EU market before 12 August 2026 may remain on the market without withdrawal. Stock placed after 12 August 2026 must comply immediately — there is no stock transition period. Ordering patterns and buffer stock should be sized accordingly; building inventory in July 2026 of non-compliant film for sale in late 2026 would not be permitted.