From 12 August 2026, food-contact packaging placed on the EU market cannot contain PFAS above 25 ppb for any single substance (targeted analysis), 250 ppb for total targeted PFAS, or 50 ppm total fluorine including polymeric PFAS. UK rules do not match this yet, but DEFRA's February 2026 PFAS Plan signals tighter UK testing and possible REACH restrictions. If you ship to the EU, supply UK brands that export, or simply want to de-risk your menu, you need to be reformatting your packaging spec this summer.
PFAS (per- and polyfluoroalkyl substances) are a family of around 14,000 synthetic chemicals nicknamed "forever chemicals" because they don't break down in the environment. In foodservice packaging, they were the easy answer for one problem: keeping grease, oil and moisture from punching through paper. A thin PFAS coating gave a chip wrapper, a burger box or a pastry bag the barrier of plastic without the look or weight of plastic.
The problem is that the same stability that makes them useful in packaging makes them dangerous in the body and in waste streams. A 2020 study cited by the campaign group PFAS Free UK found PFAS in packaging from 8 of 9 major UK supermarkets and in 100% of the takeaways tested. More recent UK monitoring referenced in the DEFRA PFAS Plan suggests PFAS presence in mainstream UK takeaway boxes has fallen since 2020. The risk now sits in legacy products and imported lines.
The EU's Packaging and Packaging Waste Regulation, Regulation 2025/40, entered into force in February 2025. From 12 August 2026, food-contact packaging cannot be placed on the EU market if PFAS exceed three thresholds.
Two practical points. First, there is no transition period. Stock manufactured before 12 August 2026 still cannot be placed on the market after that date if it fails the limits. Second, the regulation comes with a stepwise testing approach because validated analytical methods are still being finalised, as explained in Food Safety Magazine's deadline guide. The Step 1 screen is total fluorine: if a sample is under 50 ppm total fluorine, it passes without further work.
The UK has not adopted the EU thresholds. The closest equivalent right now is voluntary: EN 13432 compostability caps total fluorine at 100 ppm, a limit baked into TUV Austria's OK Compost certification schemes from January 2022. If your packaging carries a current OK Compost mark, it has already been screened to that 100 ppm ceiling.
Beyond that, the UK landscape is changing. DEFRA's first PFAS Plan, published 3 February 2026, commits to four packaging-relevant actions: developing PFAS testing methods for food contact materials, expanding sampling, considering a UK REACH restriction on PFAS in consumer articles including packaging, and reviewing dietary exposure data. None of that is a hard limit yet, but combined with retailer pressure and the EU divergence problem for exporters, the direction is one-way.
If you run a cafe, a takeaway or a multi-site delivery brand, these are the lines worth checking with your supplier:
You have three serious options to replace PFAS-coated paper, and they handle grease in different ways.
Bagasse and moulded fibre. Sugarcane bagasse is the residue left over after juice is pressed for sugar. It is a fibre, not a coating, so grease resistance comes from the structure of the moulded wall itself rather than a chemical layer on top. Tocco and Kemira both rank bagasse as a first-tier replacement for fried foods and saucy dishes. Look for EN 13432 or BPI certification on the sales sheet; that confirms total fluorine under 100 ppm.
Aqueous-coated paper. Water-based dispersion barriers from suppliers like Solenis (TopScreen) and Koehler Paper replace plastic and PFAS coatings on kraft and greaseproof paper, as documented by Food Engineering. Aqueous coatings give you grease and moisture resistance without intentionally added PFAS, and the paper stays recyclable in standard paper streams (unlike PE-lined paper, which mostly does not).
Seaweed-based barrier coatings. UK company Notpla won the Earthshot Prize in 2022 for its seaweed coating that replaces plastic and PFAS lining on takeaway boxes. Premium price point, strong sustainability story, currently best for brands that lead on environmental positioning.
Three steps, in this order:
Does the EU PFAS ban apply to me if I only sell in the UK?
Not directly. The 12 August 2026 limits apply to packaging placed on the EU market. If you only sell UK domestic, you have more time, but DEFRA's PFAS Plan, ASA scrutiny of green claims, and retailer pressure are all pushing UK supply chains in the same direction. Switching now removes a known regulatory risk for very little incremental cost.
Is bagasse always PFAS-free?
Bagasse fibre itself contains no fluorinated chemicals. The question is whether the manufacturer adds a PFAS coating for extra grease resistance. EN 13432 / OK Compost certified bagasse caps total fluorine at 100 ppm, well inside even strict reading of the EU rule. Always ask for the certificate.
Are PLA-lined paper cups PFAS-free?
The PLA lining itself is PFAS-free, but PLA cups whose dominant material is plastic remain liable for the UK Plastic Packaging Tax when the plastic component contains less than 30% recycled content, because PLA is classified as plastic for PPT purposes. PFAS-free does not equal tax-free or home-compostable. See our UK Plastic Packaging Tax guide for the tax side.
What's the difference between "PFAS-free" and "fluorine-free"?
Most regulators use them interchangeably for food contact materials. The EU rule sets a total fluorine ceiling of 50 ppm because fluorine is the analytical marker for PFAS. A product labelled "fluorine-free" or "no intentionally added PFAS" should pass.
Are aqueous coatings recyclable?
Yes, generally. Aqueous (water-based) dispersion coatings let the underlying paper or board stay recyclable in standard kerbside paper streams, subject to your local council's rules. They are not the same as PE (polyethylene) plastic lining, which causes problems in paper recycling.
Does microwaving release PFAS from coated paper?
Microwave popcorn bags were the original PFAS food packaging concern because heat accelerates migration into food. Even at room temperature, PFAS can migrate, which is why the EU rule covers all food-contact packaging not just hot-fill formats.
How quickly can I switch?
For lines where Element holds stock, you can switch on the next order. For custom-printed lines, the typical lead time is 6 to 10 weeks for printing plus shipping. If you sell into the EU, start the conversation with your supplier now to land replacement stock comfortably before 12 August 2026.
Where do PFAS go after the bin?
That is the second reason the rule matters. PFAS persist in soil and water indefinitely, and contaminate the compost stream when "compostable" packaging carries fluorinated coatings. BIOPAP's policy paper sets out why the composting industry treats PFAS-containing items as non-compostable regardless of certification claims.
The 12 August 2026 deadline is real, with no grace period for stock in market. The UK rules will follow even if more slowly. Switching grease-resistant paper from PFAS-coated to bagasse, aqueous-coated paper or seaweed-based barriers takes a single conversation with your supplier. Browse our compostable foodservice range or ask us for PFAS test reports on any line you currently stock.
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