August 12, 2026: EU PFAS Rules for Food-Contact Packaging

Last reviewed: 11 August 2026

From 12 August 2026, Article 5(5) of Regulation (EU) 2025/40 establishes PFAS concentration limits for food-contact packaging placed on the European Union market. This provision is not a universal ban on polyethylene bags or on every package entering the EU.

Official source: Regulation (EU) 2025/40 on packaging and packaging waste — EUR-Lex . Readers should consult the current consolidated text and any applicable implementing guidance before making a compliance decision.

What the 12 August 2026 Requirement Covers

Article 5(5) states that food-contact packaging may not be placed on the EU market when it contains PFAS at or above the applicable concentration limits, subject to the conditions stated in the Regulation.

The Regulation specifies the following limits:

• 25 ppb for any PFAS measured by targeted PFAS analysis, with polymeric PFAS excluded from quantification
• 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors, with polymeric PFAS excluded from quantification
• 50 ppm for PFAS, including polymeric PFAS; where total fluorine exceeds 50 mg/kg, the documentation requirement stated in Article 5(5)(c) should also be reviewed

The legal text, analytical method, detection limits and interpretation should be reviewed with a qualified laboratory or EU regulatory specialist. A general supplier statement is not a substitute for evidence matched to the finished package.

This Is Not a Ban on All PE Packaging

Polyethylene itself is not automatically prohibited. Article 5(5) addresses PFAS concentration in applicable food-contact packaging, not the general use of LDPE, LLDPE or HDPE.

Non-food applications, including apparel, electronics and industrial packaging, are not automatically covered by this food-contact provision. Other EU chemical, packaging and product-specific requirements may still apply. The intended use and complete package should therefore be defined before a compliance conclusion is made.

Virgin PE Does Not Automatically Establish PFAS Compliance

Virgin resin may provide a more controlled material baseline, but a finished package can contain components in addition to its base polyethylene resin. Components requiring review may include:

• Processing aids and functional additives
• Slip, anti-block and anti-static formulations
• Color masterbatch and pigments
• Printing inks and coatings
• Adhesives, labels, zipper profiles and sliders
• Materials exposed to shared production equipment

A statement that a film uses 100% virgin PE does not independently establish that the complete finished package is below the applicable PFAS limits.

Recycled PE Should Be Evaluated, Not Automatically Rejected

Recycled-content PE may require additional feedstock and traceability review. This does not mean that all recycled PE contains PFAS or that recycled-content packaging automatically fails EU requirements.

A project-specific review may consider:

• Feedstock origin and recycled-material grade
• Supplier qualification and contamination controls
• Batch and chain-of-custody traceability
• Suitability for the intended food-contact conditions
• Material declarations and laboratory evidence

Recycled content and PFAS compliance are separate questions. Each should be evaluated against the finished-product specification and applicable evidence.

Define Responsibility Before Production

Responsibility may involve the manufacturer, importer, brand owner, distributor or another economic operator, depending on how the packaging or packaged product is placed on the EU market. Procurement and compliance teams should define before production:

• The intended food-contact application and conditions of use
• The destination market
• The applicable PFAS limits and analytical method
• The materials and components included in the review
• The party responsible for declarations and testing
• The approved sample and production-batch identification
• The procedure for material, formulation or supplier changes

Declarations, Testing and Traceability Serve Different Purposes

A supplier declaration can document formulation information and upstream material statements. Laboratory testing evaluates the submitted sample using a defined method and detection limit. Traceability connects the evidence to the material and production batch supplied.

A project compliance file may include:

• The approved finished-product specification
• Resin, additive, colorant and ink declarations
• A statement concerning intentionally added PFAS
• A finished-product laboratory report where required
• The test method, detection limits and sample identification
• Material and production-batch traceability records

Evidence should remain connected to the exact construction supplied. A report for unprinted transparent film should not automatically be applied to a printed, colored or otherwise modified bag.

Practical Preparation

1. Identify packaging intended for food-contact use in the EU.
2. Separate food-contact projects from non-food applications.
3. Review resin, additives, masterbatch, inks and other components.
4. Define the required declarations and analytical testing.
5. Approve a finished sample representing the commercial specification.
6. Connect evidence to the relevant material and production batch.
7. Establish change-control requirements with the supplier.
8. Confirm the final interpretation with a qualified EU specialist.

Flexon Pack's Project-Specific Approach

Flexon Pack is the international B2B packaging brand operated by Dongguan Chenghua Industrial Co., Ltd. The legal entity was incorporated in 2015, and its packaging operations trace to 2012.

Virgin LDPE, LLDPE and HDPE are standard material options. Qualified recycled-content PE and other formulations are managed as separate programs when expressly specified and technically suitable.

PFAS-related declarations and testing requirements are reviewed against the confirmed resin, additives, colorants, inks, finished construction, intended application and destination market. Documentation applies only to the identified product and evidence scope.

Review Flexon Pack's compliance evidence or request an EU food-contact packaging review.

Official Reference

• European Union: Regulation (EU) 2025/40 on packaging and packaging waste , particularly Article 5(5)

This article provides general procurement information and is not legal advice. Requirements, amendments, official interpretations and the applicability of the Regulation should be confirmed before packaging is placed on the EU market.