EU PPWR FAQs Updated August 2026 - Flipbook - Page 22
acts to amend the limit established in Article 5(4), but only to lower the permitted sum of
concentration levels. The Commission is not empowered to extend the application date of the
heavy-metal restrictions laid down in the PPWR.
15) Will Regulation (EC) 1935/2004 on food contact materials, Regulation (EU)
10/201112on plastic articles intended to come into contact with food, Regulation (EU)
2019/1021 on persistent organic pollutants and the REACH regulation be amended
by reference to the PPWR's ban on PFAS?
The PPWR does not establish a PFAS ban but rather sets maximum concentration levels. Also, it is
not provided that the PFAS limits in the PPWR would be taken over into other, 8vertical9, EU
legislations. Based on Article 5(5), the Commission will carry out an evaluation to assess the need
to amend or repeal the PFAS restriction in the PPWR in case of identified overlaps with restrictions
or prohibitions on the use of PFAS under the FCM Regulation, the REACH Regulation or the POPs
Regulation.
16) Do the PFAS restrictions in Article 5(5) apply both to intentionally added and
unintentionally present PFAS?
The PFAS restriction adopted by the PPWR does not differentiate between intentionally added and
unintentionally present PFAS. Therefore, the provisions in Article 5(5) apply to both. To be noted,
preliminary PFAS laboratory analyses results on a number of selected packaging13showed that in
practice only packaging where PFAS have been intentionally added would give results above the
PFAS limit values.
17) Do the restrictions apply only to materials used in packaging manufacturing or also
to the materials and the associated inks, varnishes, glues and adhesives?
The limits apply to the packaging unit as a whole, including the associated inks, varnishes, glues
and adhesives placed on the market by the manufacturer. The latter is the person responsible for
drawing the technical documentation needed to prove compliance (for further information, see
Commission guidance document).
18) Will a list of the PFAS concerned by the ban (with CAS numbers for identification)
be published?
A list of PFAS subject to this restriction will not be published. The limits apply to all PFAS falling
under the definition provided in the PPWR and possibly contained or contaminating the packaging.
19) How will the PFAS limits be enforced, considering there are no harmonised
methodologies for PFAS in food-contact packaging at EU level?
12
Regulation (EU) No 10/2011 of 14 January 2011 on plastic materials and articles intended to come into contact with
food (OJ L 012 15.1.2011)
13
Skedung L.1 and Bjarnemark F.1 : A Harmonized Workflow for PFAS Compliance Testing under EU Packaging
and Packaging Waste Regulation and Emerging Universal Restrictions: A Food Contact Packaging Case Study.
1RISE Research Institutes of Sweden
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