PFAS, Food Contact and Barrier Coatings: A Buyer’s Guide

Papironova Lens   Regulatory & Material Insight

Grease-resistant paper can look simple.

A takeaway box holds a burger.A wrapper contains oily food.A bakery paper prevents grease from penetrating the sheet.

But behind that apparently simple performance is a much more important question:

What chemistry is providing the barrier?

For European buyers of food-contact paper, board and packaging, that question has become particularly important.

From 12 August 2026, the EU Packaging and Packaging Waste Regulation   Regulation (EU) 2025/40, or PPWR   restricts PFAS in food-contact packaging above specified concentration limits.

For buyers, importers, converters and packaging companies, barrier performance can therefore no longer be evaluated independently from chemical composition, food-contact suitability and supporting documentation.

What Are PFAS?

PFAS stands for per- and polyfluoroalkyl substances.

It describes a very large family of fluorinated chemicals valued for properties including resistance to:

• grease;

• oil;

• water;

• heat; and

• chemical degradation.

Those characteristics made certain PFAS useful in a range of industrial and consumer applications, including some food-contact packaging.

Examples historically associated with PFAS-based grease resistance include:

• fast-food wrappers;

• bakery papers;

• takeaway packaging;

• microwave popcorn bags;

• pizza packaging; and

• other grease-resistant food-contact materials.

Their chemical persistence, however, has created significant environmental and health concerns.

This is why Europe has moved to specifically restrict PFAS concentrations in food-contact packaging.

What Changed in August 2026?

Under Article 5(5) of the PPWR, from 12 August 2026, food-contact packaging may not be placed on the EU market if it contains PFAS at or above specified limits, unless another Union legal act already prohibits the relevant concentration.

The PPWR establishes three thresholds:

25 ppbfor any PFAS measured using targeted PFAS analysis, excluding polymeric PFAS from that quantification.

250 ppbfor the sum of PFAS measured using targeted analysis, where applicable following degradation of precursors, again excluding polymeric PFAS from that quantification.

50 ppmfor PFAS including polymeric PFAS, with additional documentation requirements concerning fluorine where total fluorine exceeds 50 mg/kg.

For professional buyers, the practical message is straightforward:

“PFAS-free” should no longer be treated merely as a marketing claim.

For food-contact packaging entering the European market, PFAS content is now a compliance issue.

There Is No General Sell-Through Period for New Placements

This point is particularly important for importers.

The European Commission's 2026 PPWR guidance states that the Regulation does not provide a transitional period for exhausting stocks of PFAS-containing food-contact packaging.

Packaging placed on the market after 12 August 2026 must comply with the new PFAS limits.

Packaging that had already been placed on the market before that date may remain on the market and does not need to be withdrawn solely because of this provision.

For importers and distributors, this makes the date and circumstances of placing packaging on the EU market commercially significant.

Food Contact Goes Beyond PFAS

Passing the PFAS requirement does not automatically make packaging suitable for food contact.

All food-contact materials placed on the European market remain subject to the general EU food-contact framework, including Regulation (EC) No 1935/2004.

The fundamental principle is that materials should not transfer their constituents into food in quantities that could:

endanger human health,

cause an unacceptable change in the composition of the food,

or

cause deterioration in its taste or odour.

Food-contact materials must also be manufactured according to applicable Good Manufacturing Practice requirements.

Therefore:

PFAS compliance ≠ complete food-contact compliance.

It is one part of a broader material-safety assessment.

Why Barrier Coatings Matter

Paper and board provide excellent structural and printing properties.

But cellulose fibres naturally interact with water, oils and grease.

For many food-packaging applications, the base paper therefore needs additional functionality.

A barrier can be designed to provide resistance against:

Water | Water Vapour | Oil | Grease | Fat | Oxygen | Aroma

depending on the application.

Different technologies can be used to achieve these functions.

These may include:

• polymer extrusion coatings;

• aqueous or dispersion coatings;

• functional surface treatments;

• bio-based barrier systems;

• wax-based systems;

• laminations; and

• multilayer material structures.

The important point is that these technologies are not interchangeable.

Each creates a different combination of:

Performance + Convertibility + Food-Contact Suitability + Recyclability + Cost

PE-Coated Paper

Polyethylene   PE   has long been widely used as a functional barrier for food-service packaging.

It can provide strong moisture and liquid resistance and is well understood by many converters.

Typical applications include:

• paper cups;

• food containers;

• ice-cream packaging;

• takeaway applications; and

• liquid-resistant paperboard.

Its performance is established, but conventional paper-plastic structures can introduce additional considerations regarding material separation and recycling.

This has helped accelerate interest in alternative barrier technologies.

Aqueous and Dispersion Barriers

Water-based or dispersion coatings are increasingly important in fibre-based packaging development.

Depending on their formulation, they can provide resistance to grease, oil or moisture while potentially reducing reliance on conventional extrusion-coated plastic layers.

But buyers need to be careful with terminology.

“Water-based” does not automatically mean plastic-free.

“PE-free” does not automatically mean recyclable.

“Bio-based” does not automatically mean compostable.

And:

“PFAS-free” does not automatically mean suitable for every food-contact application.

The actual formulation, coating weight, substrate, converting behaviour and end-of-life characteristics need to be understood.

Barrier Performance Must Match the Food

There is no universal food-packaging barrier.

Consider the difference between:

Dry bakery products

and

a hot takeaway meal containing oil and sauce.

Or between:

a sandwich wrapper

and

an ice-cream cup stored at low temperature.

The material requirements are different.

A professional specification should therefore consider:

Food type

Dry / moist / fatty / acidic / alcoholic, where relevant

Contact conditions

Direct or indirect contact

Temperature

Frozen / chilled / ambient / hot-fill

Contact duration

Minutes / hours / days / longer storage

Barrier requirement

Grease / oil / water / moisture vapour / oxygen / aroma

Conversion process

Printing / folding / forming / heat sealing / gluing

The barrier should be selected around the application   not the other way around.

KIT, Cobb and Barrier Performance

Buyers frequently encounter technical values when evaluating barrier paper.

Two important concepts are:

KIT Rating

The KIT test is commonly used to evaluate resistance to grease and oil penetration.

A higher value generally indicates stronger grease resistance under the test conditions.

But a KIT value should not be treated as a complete food-contact specification.

Real packaging performance depends on factors such as food composition, temperature, contact duration, folds, creases and converting conditions.

Cobb Value

The Cobb test measures water absorption over a defined period.

Lower water absorption can be desirable where moisture resistance is important.

Again, however:

Cobb is a material property   not a complete packaging-performance guarantee.

The finished structure still needs to perform under its real conditions of use.

Creasing Can Change Barrier Performance

This is an often-overlooked issue.

A coated sheet may demonstrate excellent barrier performance while flat.

Then it is:

printed → die-cut → creased → folded → glued → filled.

If the coating cracks during creasing or forming, the finished package may behave differently from the original laboratory sample.

For this reason, barrier evaluation should not stop at the flat sheet.

Where the application demands it, testing the converted package under realistic conditions can be significantly more meaningful.

What Should European Buyers Ask Their Supplier?

A professional RFQ for food-contact barrier paper should go beyond:

“Please quote PFAS-free greaseproof paper.”

Papironova recommends requesting information covering at least the following areas.

Base Material

Paper or board gradeGrammageCaliperFibre compositionSurface treatment

Barrier

Barrier technologyCoating chemistry/typeCoating weightOne-side or two-side treatmentTarget grease/oil/water performance

Food Contact

Intended food-contact applicationRelevant Declaration of Compliance or supporting documentation where applicableMigration or supporting test information as relevantTemperature and contact-time limitationsGMP-related documentation where applicable

PFAS

Supplier declaration regarding PFASRelevant analytical testing or supporting evidenceTest methodologyIdentification of the tested material and production reference

Converting

Printing compatibilityCreasing/folding behaviourHeat-sealing requirementsGlue compatibilityForming characteristics

End of Life

Recyclability evidence where claimedRepulpability evidence where relevantMaterial compositionAny specific disposal or recycling limitations

Traceability

MillProduction siteBatch/lot identificationSupporting certificationRaw-material traceability where applicable

This creates a much stronger purchasing file than simply requesting a certificate saying:

“PFAS Free.”

Testing Matters   But So Does the Test Method

The Commission's 2026 guidance recognises an important practical issue:

there is currently no single harmonised EU analytical methodology specifically for PFAS in food-contact packaging.

The Commission therefore recommends a stepwise enforcement approach involving total fluorine analysis and, where necessary, additional analytical techniques.

For buyers, this means laboratory reports should not be judged only by whether the final page says:

PASS

or

COMPLIANT.

Ask:

What was tested?

Which batch or material structure does the report represent?

Which analytical method was used?

What were the detection limits?

When was the test performed?

Does the tested construction exactly match the material being supplied?

Documentation quality is part of supplier quality.

Imported Packaging Requires Particular Attention

For companies importing food-contact paper, board or finished packaging into Europe, regulatory qualification should happen before shipment, not after arrival.

This is particularly important when sourcing from outside the EU.

A commercially attractive material can become extremely expensive if, after production or arrival, documentation is incomplete or the material does not satisfy the requirements applicable to its intended use.

A robust sourcing process should therefore follow:

Specification → Documentation Review → Sample → Testing/Validation → Converting Trial → Approval → Commercial Order

rather than:

Lowest Price → Purchase Order → Container → Compliance Questions

The order of these steps matters.

Recyclability and Food Safety Are Different Questions

A barrier coating can potentially improve recyclability characteristics while still requiring separate food-contact evaluation.

Likewise, a material can satisfy food-contact requirements without necessarily being optimal from a recycling perspective.

These are different assessments.

A future-oriented packaging specification increasingly needs to consider both:

Chemical Safety + Circularity

while still maintaining:

Functional Performance + Commercial Viability

That is one of the central challenges facing modern fibre-based food packaging.

The Papironova Lens

At Papironova, we believe food-contact barrier materials should be evaluated as complete structures.

Not simply:

Paper + Coating

but:

**Base Paper

• Barrier Chemistry

• Food Contact

• PFAS Compliance

• Functional Performance

• Convertibility

• Recyclability

• Documentation

• Traceability

• Commercial Economics**

A barrier that performs perfectly but creates a compliance problem is not a good solution.

A compliant coating that fails during converting is not a good solution.

A recyclable structure that cannot contain the product is not a good solution.

And an advanced material that doubles packaging cost without delivering relevant value may not be a commercially sustainable solution either.

The objective is to find the correct balance.

For European food packaging, that balance is increasingly clear:

Performance must be designed together with chemistry, compliance and end-of-life considerations   not evaluated afterward.

That is the new reality of barrier packaging.

Papironova

Material Knowledge | Supply Capability | Commercial Execution

Papironova supports European buyers, converters and packaging companies in evaluating paper and board according to application, barrier performance, food-contact requirements, regulatory compatibility, supply capability and commercial economics.

Papironova Lens provides technical and commercial material insight and does not constitute legal or regulatory advice. Food-contact suitability, PFAS compliance and other regulatory requirements should be verified for the specific material, coating, finished packaging, application and market concerned.