← All measuresMeasures / Packaging and Packaging Waste Regulation
Requirement · SUB-05

Where total fluorine exceeds 50 mg/kg, supply on request proof of whether the measured fluorine is PFAS or non-PFAS, so the packaging manufacturer or importer can complete its technical documentation.

Manufacturers, importers and downstream users under REACH supplying materials to packaging makers must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 5(5)(c), in the Packaging and Packaging Waste Regulation. as of 2026-08-18
  • The act gives its timing as: From 12 August 2026 (Art. 5(5)). as of 2026-08-18
  • It names one industry by name: Chemicals. as of 2026-08-18
  • Compliance is checked by technical documentation (Annex VII), per request. as of 2026-08-18
Addressee Manufacturers, importers and downstream users under REACH supplying materials to packaging makersAct Regulation (EU) 2025/40, base actArticle Art. 5(5)(c)Class Businesses

What changes

Chemicals suppliers upstream of food-contact packaging. This is the supply-chain limb of the PFAS restriction: the duty to prove the content sits one step back from the operator who has to document it.

The rule

New — no predecessor
Trigger

a request where total fluorine in the material exceeds 50 mg/kg

Obligation

Where total fluorine exceeds 50 mg/kg, supply on request proof of whether the measured fluorine is PFAS or non-PFAS, so the packaging manufacturer or importer can complete its technical documentation.

Who is affected

Addressee
Manufacturers, importers and downstream users under REACH supplying materials to packaging makers
Class
Businesses
Sectors
Names Chemicals and refining · Reaches Plastics converting, Paper and board, Food, drink and tobacco
Applies
From 12 August 2026 (Art. 5(5))

Burden drivers

D1 · D4 — 2 of 7 marks fire on this provision.

No size threshold.

Source text

Verbatim

if total fluorine exceeds 50 mg/kg the manufacturer, importer or downstream user as defined respectively in Article 3, points (9), (11) and (13) of Regulation (EC) No 1907/2006 shall, upon request, provide to the manufacturer or the importer as defined respectively in Article 3(1), points (13) and (17), of this Regulation proof of the quantity of fluorine measured as content of either PFAS or non-PFAS in order for them to draw up the technical documentation as referred to in Annex VII to this Regulation.

View source →