UK packaging industry questions how PFAS compliance will be assessed

The UK Foodservice Packaging Association is seeking clarification on how PFAS requirements will be applied under the country’s Recyclability Assessment Methodology for 2027, particularly around testing thresholds and the evidence producers will need to demonstrate compliance.

The issue is becoming increasingly important for foodservice packaging manufacturers as chemical-content requirements are being incorporated directly into packaging recyclability assessments and producer responsibility fees.

The FPA is raising the questions with PackUK as companies prepare for the practical application of RAM 2027.

25 ppb threshold can trigger a red rating

Under RAM 2027, food packaging containing more than 25 parts per billion of any individual or total PFAS is automatically assigned a red rating.

A red classification can result in less favourable treatment under the UK’s packaging extended producer responsibility system, increasing the financial pressure on producers using affected materials.

The FPA says businesses need greater clarity on how the threshold will be measured and how compliance will be demonstrated consistently across the supply chain.

Producers need to know what evidence will be accepted

Packaging manufacturers may rely on several forms of evidence when demonstrating the chemical composition of their materials.

Potential sources include supplier declarations, technical specifications, laboratory test reports and information passed through multiple stages of the packaging supply chain.

However, the FPA is seeking clarification on which types of evidence PackUK will accept and how producers should manage cases where detailed analytical information is not readily available.

This is particularly relevant to foodservice packaging manufacturers that purchase films, coatings, papers, inks, adhesives and other components from multiple suppliers.

UK and EU PFAS thresholds are not identical

The situation becomes more complex for businesses supplying both the UK and European Union markets.

Under the EU Packaging and Packaging Waste Regulation, food-contact packaging is subject to a limit of 25 parts per billion for individual targeted PFAS, 250 parts per billion for the sum of targeted PFAS and 50 parts per million for PFAS including polymeric PFAS.

The different structures of the UK RAM and EU PPWR requirements mean that the same packaging format may need to be assessed against different criteria depending on the market in which it is placed.

EU implementation also faces testing challenges

The European Commission has acknowledged that there is currently no harmonised EU-level testing methodology specifically for PFAS in food-contact packaging.

Its implementation guidance recommends a staged approach beginning with total fluorine measurement. Where total fluorine exceeds 50 milligrams per kilogram, additional analytical techniques can be used to determine whether the fluorine is organic and potentially associated with PFAS.

Direct analysis of total oxidisable precursors can then be used to assess compliance with the specific PFAS concentration thresholds.

Chemical composition becomes part of recyclability assessment

The FPA is also questioning the relationship between chemical-content thresholds and recyclability ratings.

A packaging structure may be technically capable of being collected, sorted and reprocessed, but still receive a poor RAM rating if it exceeds the applicable PFAS threshold.

This means that chemical composition can have a direct economic effect on packaging through producer responsibility fees, even where the material performs well within physical recycling processes.

Supply-chain transparency becomes more important

The issue highlights the growing importance of detailed material information throughout the packaging supply chain.

Converters and foodservice packaging producers increasingly need reliable information about coatings, inks, adhesives, polymers and other components used in their products.

Without consistent documentation, companies may find it difficult to demonstrate compliance even when their packaging is designed to avoid intentionally added PFAS.

PFAS requirements are reshaping packaging design

The development is likely to increase demand for PFAS-free coatings, barriers and grease-resistant treatments across foodservice packaging.

Material suppliers are already developing alternatives that provide oil and moisture resistance without relying on fluorinated chemistry.

For packaging designers, the challenge is to combine these alternatives with the performance, recyclability and food-contact requirements expected from commercial packaging.

Regulatory divergence increases compliance complexity

The UK and EU approaches demonstrate how packaging companies operating across both markets may increasingly need to manage parallel regulatory frameworks.

While both systems are moving towards tighter control of PFAS in food-contact packaging, their thresholds, assessment methods and regulatory purposes are not identical.

For producers, clear guidance and reliable analytical methods will therefore become increasingly important as packaging compliance moves from voluntary declarations towards documented and enforceable requirements.