PPWR PFAS limits

Article 5(5) is the first substantive restriction in the Regulation to bite, and it applies now. Three separate limits govern food-contact packaging: 25 ppb for any single PFAS, 250 ppb for the sum of them, and 50 ppm including polymeric PFAS.

There is a second duty that is easy to miss. Where total fluorine exceeds 50 mg/kg, upstream REACH actors owe proof of what that fluorine actually is — so a supplier statement that stops at 'no intentionally added PFAS' does not close the question. Nothing about this obligation waits on a Commission act, which is why it belongs at the front of a PPWR programme rather than behind the recycled-content work.