(PPWR 2) PFAS and Concerning Substances: What is Now Banned in Your Packaging

Minerya
Mar 20
2 min read

Updated: Mar 25

Europe says stop to "forever pollutants" and other dangerous substances in food packaging.

Discover the complete list of bans and how to comply.

Substances Now Banned from Your Packaging

Regulation (EU) 2025/40 establishes a strict blacklist (Article 6) of substances that can no longer be used in any food contact material:

1. PFAS: The Total Ban on "Forever Pollutants"

What are PFAS?

Per- and polyfluoroalkyl substances (PFAS) are a family of over 4,000 synthetic chemical compounds. Nicknamed "forever pollutants," they never degrade in the environment or the human body.

Why are they dangerous?

Accumulate in the human body for years
Linked to cancers, fertility issues, and immune disorders
Permanently contaminate water and soil
Transmitted to the fetus and through breastfeeding

Where were they found in food packaging?

Grease-resistant packaging (pizza boxes, popcorn bags)
Parchment paper and baking paper
Non-stick coatings on utensils
Waterproof food films
Microwaveable trays

2. CMR Substances: Carcinogenic, Mutagenic, and Reprotoxic

The regulation bans any substance classified as CMR category 1A or 1B, including:

Formaldehyde: formerly used in certain resins
Benzene and derivatives: present in some printing inks
Heavy metals: lead, cadmium, mercury (except unavoidable traces < 0.01%)

3. Confirmed Endocrine Disruptors

BPA (Bisphenol A): already banned, the ban extends to all its suspect substitutes
Phthalates: DEHP, DBP, BBP, DIBP totally banned
Parabens: used as preservatives in some coatings

Specific Restrictions by Material (Articles 7-8)

For Plastics

Maximum overall migration: 10 mg/dm² (reinforced to 6 mg/dm² for infant food)
Exclusive positive list: only approved monomers and additives
Recyclability requirement for single-use packaging

For Paper and Cardboard

PFAS content: 0 (zero tolerance)
Inks: only on the non-contact side or with a functional barrier
Recycled paper: mandatory purity tests

For Metals

PFAS-free coatings mandatory
Migration tests for nickel, chrome, aluminum
Stainless steels: food-grade only

Summary Table of Bans and Deadlines

Substance/Family	Ban Date	Stock Depletion Deadline	Maximum Fines
PFAS (all)	July 1, 2025	December 31, 2025	Up to 4% of turnover
BPA and substitutes	Immediate	None	€10M or 4% of turnover
Listed phthalates	Immediate	6 months (until 06/30/25)	€10M or 4% of turnover
CMR cat. 1A/1B	Immediate	None	Up to 4% of turnover
Formaldehyde	Immediate	None	€10M or 4% of turnover
Heavy metals	Immediate*	None	€5M or 2% of turnover

*Except unavoidable technical traces < 0.01%

Urgent Actions for Your Compliance

1. Immediate Audit of Your Packaging

Request complete technical sheets from all your suppliers
Demand certificates of absence of PFAS
Verify the composition of ALL your materials

2. Anticipate Alternatives

Replace PFAS: natural waxes, aqueous coatings, PLA barriers
Substitutes for phthalates: approved bio-based plasticizers
BPA-free solutions: polyesters, polypropylene, glass

3. Mandatory Documentation

Keep for each material:

Updated declaration of compliance
Recent migration tests (< 1 year)
Substance analysis certificates
Complete supplier traceability

Controls are Strengthening

Authorities have new powers:

Unannounced company inspections
Sampling for analysis
Immediate suspension of suspect products
Publication of sanctions (name & shame)

Conclusion

An Opportunity to Innovate

While these bans present a challenge, they are also an opportunity to rethink your packaging. Consumers favor responsible companies. By anticipating these changes, you turn a regulatory constraint into a competitive advantage.

Sources: Regulation (EU) 2025/40 of January 10, 2025, Articles 6-8 and Annex I

Last updated: September 2025