PPWR Is Live: The 50 ppm Number That Decides Whether Your Pouch Enters the EU

Since 12 August 2026, food-contact packaging placed on the EU market must meet three PFAS limits under Article 5 of Regulation (EU) 2025/40: 25 ppb for any single non-polymeric PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm total fluorine. A glass jar passes these limits structurally — it contains no fluorinated chemistry — but it carries 25–30× the mass of a pouch per unit sold, which shows up in freight and in weight-based EPR fees. A flexible pouch can pass just as cleanly, but only if the grease barrier, the inks and the adhesive system are specified and tested for it. The difference is not glass versus plastic. It is inherent compliance versus documented compliance.

What actually changed on 12 August 2026

The Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40 — entered into force on 11 February 2025 and became generally applicable on 12 August 2026, replacing Directive 94/62/EC. Three things became operative on that date, and all three are documentation obligations as much as material obligations:

The practical trap is the third row. Most brands we speak to already know the PFAS numbers. Far fewer can produce a test report that maps to the specific laminate they are buying — 12 micron PET / 9 micron aluminium foil / 90 micron PE, with a specific ink set and a specific adhesive. A "PFAS-free" statement on a supplier's homepage is not that.

The Commission's own guidance recommends a stepwise testing route: measure total fluorine first; if it is below 50 ppm, the material is considered compliant and no further testing is needed. Only if total fluorine is at or above 50 ppm do you move to organic/inorganic fluorine differentiation and then to targeted PFAS analysis.

Why glass passes without trying — and what that costs

Glass is inorganic. It cannot contain PFAS, and it does not need a fluorinated grease barrier to hold a oily product. From a pure Article 5 standpoint, a glass jar is the path of least resistance. That is a real advantage and we are not going to pretend otherwise.

But Article 5 is one article in a regulation with a 2030 deadline attached to it, and glass pays its bill elsewhere.

Mass per unit. A typical 500 ml glass jar with closure runs 280–350 g. A 500 ml stand-up pouch in a 100–120 micron laminate runs 10–14 g. That is roughly a 25× difference in packaging mass per unit sold, before the product is even filled.

Freight. Empty containers move as containers. A 40HQ loaded with cartoned 500 ml glass jars carries roughly 40,000–42,000 jars — volume-bound, not weight-bound, because glass is bulky per unit of capacity. The same container loaded with printed film on rolls carries a very different number; at 9–12 g per pouch and a ~26 t payload, the arithmetic lands in the millions of pouches. With Drewry's World Container Index at 4,339perFEU∗∗andShanghai–NewYorkat∗∗4,339 per FEU** and Shanghai–New York at **8,706 per FEU (August 2026), that difference is not a rounding error per unit.

EPR. Most modulated EU producer-responsibility schemes charge per tonne by material. A 320 g jar declares 25× the tonnage of a 12 g pouch for the same number of units sold. Where the glass rate per tonne is lower than the plastic rate, that advantage is real but rarely closes a 25× weight gap on its own — and from 2030, recyclability performance grades enter the calculation as well.

Breakage. Glass in a multi-leg export chain means crate design, divider cost, and a claims rate that has to be priced into the landed cost.

None of this makes glass wrong. For premium spirits, high-value cosmetics, or products where the glass is the brand, it is the right answer. It does mean "glass is automatically compliant" is only true for one article of one regulation.

Where flexible packaging actually fails the PFAS test

Fluorinated chemistry enters a pouch through three doors, and only one of them is the film itself:

1. Grease-resistant coatings and liners. The classic case: fast food wrappers, bakery bags, and any pouch where a fluorinated treatment was added to stop oil migration. This is the door most buyers check.
2. Inks and adhesives. Solvent-based and some water-based systems can carry fluorosurfactants. A compliant film with a non-compliant ink is a non-compliant pouch.
3. Post-consumer recycled content. Recyclate streams can pick up legacy PFAS from the feedstock. This matters most for the 2030 recycled-content targets, where food-contact grades need a chain of custody, not just a percentage.

The fix is a structure code discipline: every SKU gets one identifier that pins down film, ink, adhesive, and closure, and every test report references that identifier. Without it, you get the situation we see weekly — a supplier sends a beautiful PFAS report for a structure that is not the one on your purchase order.

Glass jar vs. multi-layer laminate vs. mono-material pouch

A note on the 2030 column, because it is the one that gets misquoted: recyclability grades A/B/C (≥95%, ≥80%, ≥70% recyclable by weight) apply from 2030, and Grade C is phased out by 2038. The detailed assessment criteria are still coming through delegated acts due by 1 January 2028. So today's job is to avoid locking yourself into structures that cannot plausibly reach Grade B — not to certify a grade you cannot yet be assessed against.

How to specify a PFAS-compliant pouch in five steps

1. Freeze the structure. Film gauges, ink system, adhesive, closure, valve. One code per SKU.
2. Request a total-fluorine screening on that exact code. Below 50 ppm, the Commission's guidance says you are done.
3. Above 50 ppm, escalate to organic/inorganic fluorine differentiation, then targeted PFAS analysis against the 25 ppb and 250 ppb limits.
4. Collect the declaration of conformity and technical file per SKU, and store it where your importer of record can reach it — the obligation travels with the packaging, not with the factory.
5. Re-test on change. New ink, new recyclate source, new adhesive supplier means the old report is void.

Where NSTAR Packaging works with food brands, this is the sequence we run before a structure is released for artwork — the material set (PET, OPP, PE, VMPET, AL, PA) is fixed first, then the compliance file is built around it, because a compliance file for a structure you did not order is worth nothing at the border.

FAQ

Does the PFAS restriction apply to packaging imported into the EU, or only made in the EU? It applies to packaging placed on the EU market, which includes imports. The importer of record carries the obligation to hold the declaration and technical documentation.

Is a "PFAS-free" supplier statement enough? No. The obligation is evidential. You need a test result or a documented justification mapped to the specific packaging structure, not to a material category.

My pouch uses a metallised layer, not aluminium foil. Is that a PFAS risk? Metallisation itself is not the issue. The risk sits in coatings, inks, adhesives and recyclate. Test the finished structure rather than reasoning from the layer stack.

Can a mono-material pouch hit Grade A or B in 2030? Mono-PE and mono-PP structures are the most plausible route to high recyclability grades, provided print coverage, closure material and any barrier layer are designed for the same recycling stream. The detailed criteria arrive via delegated acts by 1 January 2028.

Do glass jars have any PPWR exposure at all? Yes — heavy metals limits, declaration of conformity, the 2030 recyclability framework, and packaging minimisation rules. Glass is exempt from the PFAS problem, not from the regulation.

What does PFAS compliance add to my timeline? Testing adds days, not months, if the structure is frozen before artwork. The delay usually comes from changing structures mid-project and having to re-test.

Sources

• Regulation (EU) 2025/40 on packaging and packaging waste — EUR-Lex, OJ L 2025/40
• Measurlabs, Testing requirements under the Packaging and Packaging Waste Regulation, updated 16 August 2026 — measurlabs.com
• IntegrityNext, EU PPWR Timeline and Implementation Schedule: Key Dates, 3 July 2026 — integritynext.com
• Beveridge & Diamond, EU Packaging and Packaging Waste Regulation Begins to Apply August 12, 2026, 12 August 2026 — lawbc.com
• Drewry World Container Index, August 2026 levels as reported by CargoDuo, Ocean Freight Rates 2026 — cargoduo.com

Working on a food-contact structure for the EU market? Send us your product, fill weight, shelf-life target and destination market. We will come back with a structure code, a barrier rationale, and the compliance file that goes with it — starting from a 100-piece minimum so you can test before you commit.