New Limits Require Transparency Throughout the Supply Chain

Few topics have shaped discussions in the packaging industry over recent months and years as much as the introduction of the PPWR. The regulation must now be implemented step by step. For packaging manufacturers, it introduces a range of new obligations.

The requirements take effect in several stages. The first step is to demonstrate compliance with specific substance restrictions. Rules governing registration and extended producer responsibility will follow from 2027. Requirements relating to design for recycling, the use of recycled content, chemical recycling and reusable systems will then be introduced gradually up to 2030 and beyond, while extended producer responsibility will be expanded further.

From 12 August 2026, all packaging and packaging components must comply with a limit of 100 mg/kg for the combined concentration of lead, cadmium, mercury and hexavalent chromium. However, these requirements are not new, as Sonja Bähr, Director Business Development at the packaging design agency BPC Berndt+Partner Creality, emphasises: “The limit also had to be met under the previously applicable Packaging Directive and was already confirmed in the specifications by many suppliers.”

According to Dr Ingo Knepper, Head of RoHS, REACH and Materials Analysis Testing at DEKRA, the greatest need for action for many manufacturers is likely to concern materials containing recycled content, “as fluctuating raw-material quality can make these a source of trace contamination”. Dr Knepper therefore sees a very high need for process controls to prevent limit values from being exceeded in the finished product.

How Are the Limits Measured?

For packaging manufacturer Mondi and its customers, one of the key implementation questions has been how to assess compliance in the absence of a harmonised analytical methodology. The European Commission’s latest guidance provides a practical stepwise approach that reflects current analytical capabilities and the technical work undertaken across industry to establish a workable route for assessment. Mondi has aligned its internal risk-assessment and testing processes with this approach ahead of the August 2026 application date, explains Claudia Gluth, Head of Product Safety and Compliance Consumer Solutions at Mondi.

Packaging design and the selection of materials and suppliers are complex processes. Manufacturers should therefore consider the substance limits from the outset. “Ideally, PFAS analyses should begin during the material selection stage,” advises Dr Knepper. Analyses should be conducted on the first prototypes at the latest to determine the influence of the processing steps. DEKRA recommends a risk-based approach in which raw materials are initially classified into risk groups according to their total fluorine content, or TF, based on the 50 ppm limit.

However, measuring total fluorine also has its caveats, as Claudia Gluth explains: “Total fluorine is a useful screening parameter, but it is not specific to PFAS – fluorine can also originate from other sources.” A total fluorine concentration of more than 50 mg/kg does not therefore necessarily mean that the PFAS limit has been exceeded. “In accordance with the Commission’s tiered approach, further analyses can establish whether the fluorine is associated with PFAS or originates from inorganic or other non-PFAS sources, which in turn ensures we can prove compliance to the applicable limits”, Claudia Gluth states.

Incoming goods inspection plays an important role in monitoring potential heavy-metal contamination. “X-ray fluorescence analysis is frequently used as a rapid screening method,” explains Sonja Bähr, while also pointing out its limitations: “XRF is a surface analysis technique and cannot distinguish between oxidation states – for example, whether chromium is present as harmless Cr(III) or toxic Cr(VI). It is therefore usually only the first step in obtaining reliable evidence of compliance.”

Three groups of materials in particular carry an increased risk. These include recycled board and recovered paper, which may contain legacy substances from earlier printing processes – an issue that is becoming more significant as recycling rates increase. Printed plastics can also pose a risk, as older or lower-quality yellow, orange and red pigments may be based on cadmium or lead compounds. Although their use is now largely restricted in the EU, they remain relevant in imports and recycling streams. A further risk concerns metal packaging with chromate coatings where older coatings still contain hexavalent chromium.

Identifying and Preventing Unintentional PFAS Contamination

The PFAS limits under the PPWR apply to PFAS present in food contact packaging, regardless of whether they were intentionally added. “A declaration from our suppliers stating that no PFAS have been intentionally added is therefore important, but it represents only one part of the evidence required to demonstrate compliance,” emphasises Claudia Gluth, adding: “The assessment must also consider the structure of the particular packaging and possible unintended sources of contamination.”

According to Dr Knepper, particular attention should be paid to processing aids such as release agents, lubricants, defoamers, wetting agents and surfactants as possible sources of unintentional contamination: “These can be a source of trace contamination at ppb levels.” There is consequently a high risk of unintentionally exceeding the ppb limits because PFAS continue to be used as processing aids in the manufacture of plastics and other raw materials. “Good communication with suppliers and regular incoming goods and process controls form the basis for preventing this situation. Risk classification of materials during the development process and the early specification of second-source materials are also very important for minimising the risk,” says Dr Knepper.

Market access is a central element of the regulation. Food-contact packaging that fails to comply with the requirements may no longer be distributed. Market surveillance authorities will then be able to remove such packaging from the market. DEKRA recommends initially using batch analyses to narrow down the source of an exceedance to selected material batches or production cycles. “This is followed by a systematic root-cause analysis covering supplier information, production processes and the testing of raw materials,” Dr Knepper explains. Replacing raw materials or adjusting formulations can then often quickly restore both availability and compliance.

Mondi applies a structured, risk based approach to PFAS compliance across its own portfolio, combining detailed information from the supply chain with analytical verification. This approach is aligned with the recommendation from the regulatory bodies at European level and builds on the latest analytical methods and procedures. “The starting point is a precise understanding of the composition and risk profile of the materials we use, supported by declarations and data from our suppliers,” says Claudia Gluth. The company also conducts analytical testing at its own Mondi Food Safety Laboratory.

Alternatives Must Prove Their Performance in Practice

Developed over several decades, PFAS provided cost effective, versatile solutions that meet several requirements simultaneously. These included resistance to grease, oil and moisture, and stability when exposed to heat and moisture throughout the supply chain. When used as additives in plastics processing, PFAS also provide beneficial properties that improve material performance.

However, market-ready alternatives are available, as Sonja Bähr emphasises. She points to water-based dispersion coatings, bio-based starch systems and biopolymers such as polylactic acid (PLA). Nevertheless, these alternatives have clear technical limitations, including recyclability, Bähr states. 

Mondi is among the manufacturers using aqueous dispersion coatings. The company also supplies barrier papers with extrusion coatings and solutions offering higher barrier performance.

Some applications are inherently more demanding, particularly where high grease resistance must be combined with elevated temperatures or where high barrier performance must be reconciled with recyclability requirements. “Successful substitution means finding and implementing alternatives without compromising product protection, machine runnability or the customer’s wider packaging requirements,” says Claudia Gluth.

PFAS substitution is therefore not a universal material change. It requires reliable supply chain data, suitable analytical methods and the qualification of alternatives under actual production conditions.