EU PPWR 2025/40 for Flexible Food Packaging: PFAS, Heavy Metals and Documentation
PPWR evidence should be matched to the exact laminate, tested sample, intended use and requested scope.Understand EU PPWR 2025/40 requirements for flexible packaging, including PFAS, heavy metals, total fluorine, sample test reports and buyer documentation.
Published: 2026-07-30
What Article 5 means for flexible packaging buyers
The <a href="https://eur-lex.europa.eu/eli/reg/2025/40/oj" target="_blank" rel="noopener noreferrer">official PPWR text</a> generally applies from 12 August 2026, although individual obligations and delegated acts follow their own timelines. Article 5(4) keeps the combined concentration limit for lead, cadmium, mercury and hexavalent chromium in packaging or packaging components at 100 mg/kg. Article 5(5) introduces PFAS concentration limits for food-contact packaging placed on the EU market.
The regulation states limits for an individual targeted PFAS, the sum of targeted PFAS and total PFAS including polymeric PFAS. It also explains that total fluorine above 50 mg/kg requires evidence of the fluorine content attributable to PFAS or non-PFAS sources. Buyers should work from the current legal text, applicable guidance and the exact testing scope rather than relying on a generic statement such as “EU compliant packaging.”
Targeted PFAS and total fluorine answer different questions
Targeted PFAS analysis looks for named substances within an agreed analytical list and method. A “not detected” result means those analyzed substances were below the method reporting or detection limit. It does not automatically prove that every possible PFAS compound is absent.
Total fluorine is a broader screening measurement, but fluorine can come from PFAS and non-PFAS sources. A total-fluorine result therefore should be interpreted with its method, detection limit, sample preparation and the PPWR evidence rule. Buyers should confirm whether a report tests raw film, ink, adhesive, a finished laminate or a finished pouch because those test objects are not interchangeable.
Huasheng Packaging has third-party reports dated 30 July 2026 for one submitted BOPP/VMPET/PE laminated pouch sample. The cited reports conclude Pass for Article 5(4) heavy metals, the agreed targeted-PFAS scope under Article 5(5), and total fluorine under Article 5(5). These conclusions apply only to that submitted sample and the report scope.
A test report is not the same as EU certification
PPWR is legislation, not a single product-certification scheme that makes every material from a factory automatically approved. An ISO 22000 certificate covers a management system. A test report records results for the identified sample, analytes, method and date. A declaration of compliance or supplier statement has another purpose and should identify its applicable materials and legal basis.
For a new project, compare the requested pouch or roll film with the tested evidence:
- Exact layer sequence and film grades.
- Thickness of each layer.
- Printing ink, coating and adhesive system.
- Whether the test object is the base film, laminate or finished package.
- Intended food-contact use and filling or heat process.
- Target EU market and buyer document list.
- Report method, detection limits and test date.
If any material or process differs, do not automatically extend the old report conclusion. Review whether a new declaration, migration assessment, substance test or finished-package test is appropriate.
How buyers should build a PPWR document package
Start with a bill of materials that identifies the outer print film, barrier layer, sealant, inks, coatings, adhesive and functional components such as zippers or spouts. Map each document to a specific item instead of collecting unrelated certificates.
A practical file may include supplier material declarations, food-contact declarations where applicable, relevant migration or substance reports, heavy-metal and PFAS evidence, specifications, artwork and ink information, and a controlled record of approved changes. The final document list depends on the package, intended use, target market and customer requirements.
For printed packaging, a material change is not the only trigger for review. New ink systems, adhesives, coatings, recycled content, processing temperatures or accessory components can alter the evidence needed. Keep revision numbers and approval dates so the purchasing team, packaging converter and filling factory use the same specification.
What to send for a project-specific review
Prepare the following information before requesting a PPWR and food-contact document review:
- Product and intended food-contact application.
- Target EU country and buyer or retailer requirements.
- Pouch type or roll film format.
- Complete laminate structure and thickness.
- Printing, coating and adhesive information if known.
- Filling, sealing, pasteurization, retort or storage conditions.
- Whether the packaging contacts dry, fatty, acidic, aqueous or other food.
- Required report scope and any customer test protocol.
- Existing declarations and test reports.
- Final artwork, accessories and planned material changes.
Huasheng Packaging can compare available evidence with the proposed structure and identify document gaps. The buyer, importer or responsible economic operator should confirm the final regulatory route for the intended packaged product and market.
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Frequently Asked Questions
Is a PPWR test report an EU certification?
No. A test report records results for an identified sample, test scope, method and date. It does not certify every product or future material structure made by the supplier.
What heavy metals are covered by PPWR Article 5(4)?
The provision covers the combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components.
Does “targeted PFAS not detected” mean PFAS-free?
Not necessarily. It means the listed target substances were below the reporting or detection limit for the stated method. It should not be turned into an unrestricted PFAS-free claim.
Why is total fluorine tested?
Total fluorine can provide broader screening information, but the result must be interpreted with the method, detection limit and possible non-PFAS fluorine sources.
Can one BOPP/VMPET/PE report cover another laminate?
Not automatically. Film grade, thickness, ink, adhesive, coating, sealant and finished-package construction should be compared before deciding whether the evidence is relevant.
What should a buyer provide for document review?
Provide the complete structure, thickness, intended food contact, filling and storage conditions, target market, printing and adhesive information, accessories, existing reports and customer requirements.
When should packaging be retested?
Retesting may be appropriate when the structure, supplier, film grade, ink, adhesive, coating, processing condition or requested test scope changes. The decision should be documented per project.