PPWR 2026 – PFAS in food packaging: supplier declaration, testing control & batch hold | Word/PDF/Excel

How does the company demonstrate that food packaging complies with the new PFAS restrictions? From 12 August 2026, Article 5.5 of the EU Packaging and Packaging Waste Regulation (PPWR) (EU 2025/40) restricts PFAS in packaging intended to come into contact with food. This specialised document package helps packaging manufacturers, importers, wholesalers and food businesses request and review supplier evidence, link laboratory reports to the correct batch, stop batches with incomplete evidence, and document a manual decision.

Quick facts: Five Swedish working documents, one Swedish user guide and one English User Guide, all in editable Word (DOCX) format and with corresponding searchable, printable PDFs without interactive form fields. Also included is a Swedish-language Excel register with nine tabs and 550 formulas. 7 DOCX + 7 PDF + 1 XLSX = 15 customer files. Planned digital download as a ZIP file after manual activation.

Why is this a particularly important document template in 2026?

Packaging placed on the market from 12 August 2026 must meet PFAS requirements even if the material was manufactured earlier. There is no general transition for old stock that is first placed on the market after the date. Packaging that has already been placed on the market before 12 August may normally remain on the market. What legally counts as the first placement – e.g. for filled food packaging, service packaging or imported goods – must be assessed on a case-by-case basis. The Swedish Environmental Protection Agency's questions and answers and the European Commission's guidance explain this.

For which companies and situations?

Packaging manufacturers: Collect necessary technical documentation and check test reports, taking into account liability under Article 15 of the PPWR. Importers: Request evidence from the correct manufacturer and check that the packaging is not placed on the market without relevant documentation. Wholesalers and distributors: Document product identity and the supply chain and investigate deviations before further supply. Food businesses: Can link the correct takeaway trays, coffee cups, packaging and protective coatings to actually procured material and verified batches.

Choose a different package if the need is for general extended producer responsibility reporting, material recycling, future labelling requirements or a complete EU declaration of conformity for all PPWR articles. For broader work, see Mallbutik's PPWR Packaging Compliance Package. This package is specifically intended for PFAS evidence and batch control for food contact.

Exact file contents

Three separate PFAS limits – not a single measure

1. Individual targeted PFAS: 25 ppb for each analysed PFAS according to Article 5.5(a), where polymeric PFAS are exempt from this targeted quantification. 2. Sum of targeted PFAS: 250 ppb, where necessary with prior degradation of precursors according to Article 5.5(b). 3. PFAS including polymeric PFAS: 50 ppm according to Article 5.5(c). The prohibition signal is triggered if an applicable result is equal to or above the respective limit. The binding legal source is PPWR Article 5.5.

Total fluorine is something else: If measured total fluorine exceeds 50 mg/kg, manufacturers, importers or other concerned operators may need to obtain and provide evidence of the PFAS or non-PFAS origin of the fluorine, so that correct technical documentation can be drawn up. A total fluorine value is therefore not equivalent to the total PFAS content. A missing laboratory parameter means incomplete supporting data, not zero content.

Excel – nine tabs and 550 formulas

The workbook consists of Overview, Batches, Suppliers, Supporting Data, Analyses, Assessments, Holds, Actions and Read Me. It has fields for your own product and batch IDs, lab reports, measured results, coverage of supporting data, supplier responses, responsibilities and dated manual decisions. An empty register shows zero registered batches and analyses. No fictitious customers or laboratory results are included.

Verified test cases: A single result of exactly 25 ppb, a sum of 250 ppb or total PFAS of 50 ppm gives a HOLD SIGNAL. If one of the three results is missing, it shows MISSING ANALYSIS. Total fluorine of 52 mg/kg without explanatory evidence is shown as REQUEST FLUORINE EVIDENCE. Even complete results below the levels only give a MANUAL FINAL REVIEW – never an automatic “legal” or “approved” status.

How the company uses the files

1. Identify packaging, material, actual food contact, the operator's role and verified market date with document 01.
2. Request a product-specific, dated and traceable test report and other necessary supplier information with document 02.
3. Check all relevant measured values, units and method limitations against Article 5.5 with document 03.
4. Place an internal hold if exceeded, wrong batch, unclear analysis or missing evidence. Investigate corrective actions with document 04.
5. Make an explicit manual decision and archive the supporting data for the correct product and batch in document 05 and Excel. Perform other legally required checks separately.

Important legal limitations

The manufacturer shall, according to Articles 15 and 38–39 with applicable exceptions, perform a conformity assessment, draw up technical documentation according to Annex VII and draw up an EU declaration of conformity according to Annex VIII. According to Article 15.3, the documentation shall normally be kept for five years for single-use packaging and ten years for reusable packaging after placement on the market. Suppliers, importers and distributors have their own obligations under Articles 16–21.

This document package is not and does not issue an EU declaration of conformity. It contains no actual laboratory tests, certificates or product approvals and cannot guarantee that packaging may be placed on the EU market. Other legislation on materials in contact with food, for example EU 1935/2004 and material-specific rules, may also apply. A technically and legally responsible person must check actual results and relevant risks before release.

Frequently asked questions

Must old packaging stock meet the PFAS requirements after August 2026?

If the packaging is first placed on the EU market after 12 August 2026, Article 5.5 must be followed even if it was manufactured earlier. Packaging already placed on the market before the date may normally remain. The legal date needs to be verified.

Can we approve a supplier's statement of “PFAS-free” without a test report?

Not as an automatic technical conclusion. Request the correct documentation for material, batch, analysis method and results. What is needed depends on the packaging and the operator's legal role.

Why are both total PFAS and total fluorine in Excel?

They describe different analytical measures. PFAS including polymeric PFAS has a level of 50 ppm. Total fluorine over 50 mg/kg may involve special evidence requirements; that figure is not the same limit test.

Is it enough if the analysis result is exactly 25 ppb?

No. PPWR describes levels that are equal to or above the limit. A measurement of exactly 25 ppb for an affected individual PFAS therefore needs to be stopped and investigated in applicable cases.

Can Excel issue an approval or an EU DoC?

No. It flags deficiencies, compiles supporting data and helps with traceability, but does not perform a competent conformity assessment and generates no legal certificate.

Are the PDF files interactively fillable?

No. They are searchable and printable. The DOCX versions are editable.

Does the package contain legal templates in English?

No. The five working documents and Excel are in Swedish. English User Guide provides English instructions for the Swedish documents.

Version and official sources

Regulation (EU) 2025/40 – Article 5 and other applicable articles · Swedish Environmental Protection Agency – PPWR timeline · Swedish Environmental Protection Agency – questions and answers · European Commission – implementation guidance 2026/C 3084. Version 1.0 · 8 November 2026. AI-assisted legal source check and file QA have been carried out; no independent external legal, laboratory or authority review has been carried out.