There Is No Longer a Category Where PFAS Aren’t A Problem
Packaging was the last of our industries to get a hard deadline. It arrived this month.
By Jane Palmer, CEO, Nature Coatings
On 12 August, the PFAS restriction under the EU Packaging and Packaging Waste Regulation began to apply. Food-contact packaging above the limits can no longer be sold in the European market. The thresholds are tight: 25 parts per billion for any individual non-polymeric PFAS, 250 for the sum of them, and 50 parts per million for total fluorine including polymers.
A detail that caught some manufacturers flat-footed was that there is no grandfathering. Stock manufactured last year cannot be sold this year if it exceeds the limits. Inventory that was compliant when it was made is now unsellable in the EU.
That is a significant moment for the packaging industry, but it is not really the story. The story is the sequence.
Start with cosmetics, where the pressure came from retailers before it came from regulators. Clean at Sephora, Clean at Walmart and the equivalent programmes had PFAS on their restricted lists well ahead of any statute, which meant a brand could lose shelf access for a formulation that was still perfectly legal. Then the regulatory side caught up. Anyone who has formulated a waterproof mascara knows why this bites: the water resistance consumers expect has historically come from fluorochemistry, the same family of compounds used to coat a rain jacket.
Textiles came next and arguably hit hardest, because PFAS in apparel is not confined to one function. Durable water repellent finishes are the obvious case, but the restricted substance lists that brands now impose on their suppliers reach considerably further than that, and the EU Strategy for Sustainable and Circular Textiles keeps tightening around them. Mills have spent several years reformulating finishes they had used for decades.
Now packaging. And the pattern is not subtle.
Meanwhile the United States is producing a patchwork rather than a floor. California has legislated PFAS out of food packaging by January 2028. New Jersey passed its Protecting Against Forever Chemicals Act in April. Maine and Minnesota have their own regimes with their own timelines and their own definitions. For a company selling nationally, that is not one compliance project. It is several, each with a different deadline.
And sitting behind all of it is the proposal that five European countries put to ECHA to restrict PFAS as a class rather than substance by substance. Whatever shape that eventually takes, the direction is not ambiguous. The sectoral deadlines arriving now are a preview.
Here is what I think manufacturers are getting wrong about this.
The expensive part is not any individual ban. It is the treadmill. Every restriction triggers a reformulation cycle, and a reformulation cycle means requalifying a formula, rerunning stability testing, recertifying with retailers, updating dossiers in every market you sell into, and explaining to your customers why the product changed. Companies are budgeting for the deadline in front of them and treating it as a one-off. Then the next category's deadline arrives and they do it again. Some of the brands we work with are on their third pass through this on the same product line.
Printing inks count toward the total fluorine number that a converter has to certify, which means what is in your black is now part of a calculation it was never part of before. And BioBlack has never contained PFAS, in any formulation, in any of the industries we supply. Not because we anticipated the regulations, but because there was never a reason to put fluorochemistry in a pigment made from wood waste.
That is the whole argument, an input that was never in scope does not need reformulating when the scope changes. When the packaging deadline landed this week, none of our customers had to do anything. When cosmetics tightened, the same. When textiles did, the same again.
If you are looking at your own materials and trying to work out which of them will pull you back onto the treadmill in three years, that is a worthwhile afternoon. We are happy to help with the part of it that aligns with our hard won expertise.