COMPLIANCE GUIDE · 3 min read

From PFAS Restrictions to Recycled Content Requirements: Why Paper Packaging May Be the Easier Choice Under the EU's New PPWR Rules

New EU limits on PFAS in food-contact packaging, effective August 12, 2026, make paper-based materials an easier compliance path than plastics that rely on restricted coatings.

From PFAS Restrictions to Recycled Content Requirements: Why Paper Packaging May Be the Easier Choice Under the EU's New PPWR Rules

The EU's new PPWR requirements are not only about reducing empty space in e-commerce packaging.

Another important restriction took effect on August 12, 2026: food-contact packaging containing PFAS above the permitted limits can no longer be placed on the EU market.

PFAS—often referred to as "forever chemicals"—have historically been used in certain food-service and grease-resistant packaging, including takeaway containers, fast-food paper packaging, and pizza boxes.

This article explains what the PFAS restriction covers, why paper-based packaging can be easier to manage from a compliance perspective, and what additional regulatory costs plastic packaging may face in the coming years.

What Are PFAS, and Why Did the EU Specifically Target Them?

PFAS stands for per- and polyfluoroalkyl substances—a large group of man-made chemicals.

They are extremely persistent and do not break down easily in the environment, which is why they are often described as "forever chemicals."

Because of concerns about their persistence and their potential links to various health and environmental risks, the EU has introduced restrictions covering their use in certain food-contact packaging applications.

When Did the Rule Take Effect, and What Packaging Does It Cover?

From August 12, 2026, food-contact packaging containing PFAS above the permitted limits can no longer be placed on the EU market.

PFAS have traditionally been used where packaging needs water-, oil-, or grease-resistant properties. Examples can include takeaway food containers, fast-food wrappers, and pizza boxes.

In the past, some paper or composite packaging materials used PFAS-based treatments or coatings to achieve the kind of performance needed to prevent greasy food from soaking through or leaking.

If your products involve food or similar contact applications—such as snacks, bakery products, or cosmetics that may come into contact with the lips—this is a requirement worth understanding now.

Why Can Paper-Based Packaging Be Easier to Manage?

One important point needs to be clarified: paper packaging is not automatically PFAS-free simply because it is made from paper.

However, paper-based packaging can often achieve the required performance through alternative materials and processes, such as specially engineered fiber structures or PFAS-free coatings.

That means brands can source paper packaging designed without relying on PFAS chemistry.

Compared with a packaging format that previously depended on PFAS-containing coatings or treatments, switching to compliant alternatives may involve less material reformulation and fewer changes across the supply chain.

For brands currently using packaging that relies on restricted PFAS treatments, however, the process may require reviewing material specifications, verifying chemical content, qualifying new suppliers, or testing alternative coatings—all of which can add time and cost.

Besides PFAS, What Other Rules Could Increase the Compliance Burden on Plastic Packaging?

From 2030, different categories of plastic packaging will be required to contain minimum levels of recycled content, with percentages varying by packaging type and application.

Depending on the category, the required recycled content can range from 30% to 65%.

This means the future cost of plastic packaging may involve more than simply buying the material itself. Businesses may also need to deal with sourcing qualified recycled content, verifying the supply chain, and maintaining the documentation needed to demonstrate compliance.

Paper packaging, meanwhile, operates within a relatively well-established recycling and recovered-fiber system.

What Does This Mean for Brands Choosing Packaging Materials?

The overall message of the new EU rules is not simply that "plastic can no longer be used."

Instead, the regulatory system is adding more compliance requirements to certain types of plastic packaging—from restrictions on specific substances to recycled-content requirements and recycling-related obligations.

Paper-based packaging is not automatically the right solution for every product. But because of its material characteristics and its established recycling infrastructure, it can often be easier to fit into the direction EU packaging policy is taking.

So this is becoming less of a simple "Should we use sustainable packaging?" question and more of a business question: which packaging material is likely to carry the lowest compliance burden over the next several years?

Reviewing your packaging strategy now may help you avoid additional compliance costs that could otherwise emerge later.

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