PFAS-Free Packaging: What the New EU and US Regulations Mean for Food Service Operators

The direct answer for buyers: if any of your food packaging relies on fluorinated grease barriers, EU and US state regulations now require you to replace it — and the paperwork trail matters as much as the product. Standard PE, PLA, and aqueous coatings are PFAS-free; the risk sits in specialty grease-resistant treatments.

PFAS — per- and polyfluoroalkyl substances — have been used in food packaging for decades as grease and moisture barriers. But regulatory pressure is accelerating on both sides of the Atlantic, and food service operators who haven't yet audited their packaging supply chain should do so now.

What Are PFAS and Why Do They Matter?

PFAS are a group of over 10,000 synthetic chemicals characterised by strong carbon-fluorine bonds. They are exceptionally resistant to heat, water, and grease — which is why they have been widely used in food packaging, non-stick cookware, and waterproof textiles.

The problem: PFAS do not break down in the environment or in the human body. They accumulate over time and have been linked to a range of health concerns including thyroid disruption, immune system effects, and certain cancers. They are commonly referred to as "forever chemicals."

In food packaging, PFAS have historically been used as a coating or additive in paper cups, food wrappers, and takeaway containers to prevent grease and moisture penetration. Standard PE and PLA coatings do not contain PFAS — but some grease-resistant coatings and certain fluorinated barrier treatments do.

EU Regulation: The REACH Restriction

In February 2023, five European regulatory agencies submitted a universal PFAS restriction proposal under the EU REACH regulation. This proposal, if adopted, would restrict the manufacture, use, and import of virtually all PFAS substances across the EU — including those used in food packaging.

The restriction is expected to be phased in over 5–12 years depending on the substance and application. However, many major retailers and food service brands are already requiring PFAS-free documentation from their packaging suppliers ahead of the formal deadline.

Additionally, the EU Food Contact Materials regulation (Regulation (EC) No 1935/2004) requires that all food contact materials, including paper cups, do not transfer substances to food in quantities that could endanger human health. PFAS migration from packaging to food is increasingly scrutinised under this framework.

US Regulations: State-Level Action

In the absence of federal PFAS legislation, several US states have enacted their own restrictions on PFAS in food packaging:

• California — AB 1200 (effective January 2023) prohibits PFAS in food packaging. California's DTSC has published a list of regulated substances.
• New York — Effective December 2022, PFAS are prohibited in food packaging.
• Washington, Colorado, Maine, Maryland, Minnesota, Vermont — All have enacted or are implementing PFAS-in-food-packaging restrictions.

If you are selling into any of these markets, your packaging must be PFAS-free — and you should be able to provide documentation to prove it.

What Does "PFAS-Free" Mean in Practice?

A packaging supplier claiming PFAS-free products should be able to provide:

• A declaration of compliance confirming no intentional addition of PFAS substances
• Test results from an accredited laboratory showing PFAS content below detection limits (typically <20 ppm total organic fluorine)
• Material safety data sheets for all coating materials used

Standard PE-coated, PLA-coated, and aqueous-coated paper cups from reputable manufacturers do not contain PFAS. The risk is higher in grease-resistant coatings used for food wrappers, pizza boxes, and some food containers.

Action Steps for Food Service Operators

1. Audit your current packaging — Ask your supplier for a PFAS declaration for all food contact packaging items.
2. Prioritise high-risk items — Grease-resistant wrappers and containers carry higher PFAS risk than standard paper cups.
3. Request documentation — A verbal assurance is not sufficient. Get written declarations and test reports.
4. Check state requirements — If you operate in California, New York, or other regulated states, ensure compliance now.
5. Communicate to customers — PFAS-free packaging is increasingly a purchasing criterion for corporate cafeterias, healthcare facilities, and sustainability-focused brands.