PPWR and PFAS: What Companies Must Know Now

• PFAS requirements under PPWR focus on transparency and proof, not assumptions or generic declarations.
• PFAS exposure often sits in hidden packaging layers, making supplier transparency essential.
• PFAS is not an isolated issue – it is a stress test for PPWR data, processes, and governance as a whole.
• osapiens helps companies centralize PFAS data once and reuse it across PPWR, REACH, and future regulations.

PFAS (per- and polyfluoroalkyl substances) sit at the intersection of environmental concern, chemical regulation, and product safety. Their persistence and potential health impacts have placed them under increasing regulatory scrutiny across the EU and beyond. Within the context of the PPWR, PFAS become particularly relevant for food-contact packaging, where chemical safety expectations are highest and documentation requirements most demanding. While PPWR does not introduce a blanket ban on PFAS, it fundamentally changes what companies must know and prove about their packaging.

For many organizations, this represents a shift in mindset. PFAS considerations were often addressed through assumptions or narrow regulatory checks. Under PPWR, this is no longer sufficient. Companies must understand whether PFAS are present in relevant packaging. They must be able to demonstrate compliance where limits apply. The absence of clear evidence becomes a risk in itself.

What PPWR requires for PFAS in packaging

PPWR places its PFAS-related requirements primarily within the framework of chemical safety for food-contact packaging. Companies must identify which packaging formats fall within scope, assess their material composition, and document whether the chemicals are used and, if so, whether they remain within permitted thresholds.

This obligation does not depend on intent or likelihood. If PFAS cannot be reliably ruled out, companies are expected to investigate and document their findings. This means that uncertainty must be resolved through data collection, verification, or testing. PPWR therefore turns PFAS from a background concern into a documented compliance topic.

Why PFAS compliance is difficult in practice

PFAS rarely appear where companies expect them. They are often used in coatings, barrier layers, inks and processing aids. These are areas where material transparency is limited and documentation is fragmented. Many organizations lack visibility beyond their first-tier suppliers. Furthermore, even these suppliers may rely on sub-suppliers for critical components or processes.

As a result, PFAS declarations are often incomplete, outdated, or based on broad assumptions. Under the PPWR, these gaps become visible — and risky. Companies must demonstrate control over their packaging materials, even when the relevant information is several steps upstream in the supply chain.

PFAS as a stress test for PPWR readiness

PFAS compliance reveals whether a company’s PPWR approach is robust or superficial. Organizations that rely on ad hoc supplier requests, scattered documentation, or informal confirmations will quickly encounter limitations. The same data gaps that complicate recyclability or minimization assessments can be critical when chemical safety is involved.

In this sense, PFAS is not an exception to PPWR but rather a stress test. The substance reveals whether packaging data is structured, if supplier collaboration is effective, and if compliance processes can withstand scrutiny. Companies that struggle with PFAS often struggle with PPWR more broadly, as both rely on the same underlying capabilities.

PFAS beyond PPWR

The PPWR is just one part of the rapidly changing regulatory landscape for PFAS. Restrictions under REACH and POP regulations, as well as national bans, and international initiatives, continue to expand. Therefore, treating PFAS as a standalone PPWR task leads to duplication and inefficiency.

In contrast, structured PFAS data collected in the context of the PPWR can support compliance across multiple frameworks. When important information about materials, suppliers, and tests is managed in one place, companies can respond more efficiently to requirements from different laws. This reduces the risk of inconsistent disclosures.

Building a structured approach to PFAS readiness

A systematic approach is required to reduce PFAS-related risk. In practice, this means establishing a clear, step-by-step process that covers all critical compliance checkpoints:

• Identify relevant packaging formats – Determine which food-contact packaging and other high-risk formats are in scope and require closer scrutiny.
• Map materials and components in detail – Break down materials and components to a sufficient level of granularity to identify where PFAS could potentially be present.
• Request PFAS-specific supplier declarations – Go beyond generic compliance statements and obtain targeted PFAS declarations, supported by verifiable evidence.
• Verify where uncertainty remains – Where information gaps persist, request additional documentation or initiate testing to substantiate supplier claims.
• Document results in a consistent and traceable way – Ensure all findings, declarations, and verification steps are recorded in a structured, auditable format.
• Maintain compliance as an ongoing process – Treat PFAS compliance as a continuous effort that evolves with regulatory updates and product changes, rather than a one-time exercise.

How osapiens supports PFAS management

Trusted by over 2200 companies worldwide, the osapiens HUB supports companies in managing PFAS as part of their broader product compliance efforts. By centralizing material data, supplier declarations, and test results, organizations can see their entire packaging portfolio and reduce duplication across regulations.

This integrated approach enables companies to address PFAS as part of a scalable compliance framework that supports the Packaging Products Regulation (PPWR) today and prepares for future chemical regulations.

Want deeper guidance on PFAS readiness? Download the osapiens PFAS Guide to explore practical strategies for managing PFAS risks across packaging and product compliance.