PPWR and PFAS: What Should EU Buyers Ask a Bagasse Supplier?
Since 12 August 2026, Article 5 of Regulation (EU) 2025/40 (PPWR) limits PFAS in food-contact packaging placed on the EU market to 25 ppb for any single PFAS, 250 ppb for the sum of PFAS and 50 ppm for PFAS including polymeric PFAS. Ask a bagasse supplier for five documents: a total-fluorine report and a targeted PFAS report on the fibre body, identification of the tested specimen, a grease barrier declaration and a food-contact test report.
PPWR Article 5: three PFAS limits
Regulation (EU) 2025/40 on packaging and packaging waste. Food-contact packaging at or above any of these concentrations may not be placed on the EU market.
| Limit | Applies to | Note |
|---|---|---|
| 25 ppb | Any single PFAS, measured by targeted analysis | Polymeric PFAS excluded from this measurement |
| 250 ppb | Sum of PFAS, measured as the sum of targeted analysis | Polymeric PFAS excluded from this measurement |
| 50 ppm | PFAS including polymeric PFAS | If total fluorine exceeds 50 mg/kg, the supplier must be able to show, on request, how much of it is PFAS |
In force since 12 August 2026
The limits apply from the PPWR's general application date, 12 August 2026, to food-contact packaging placed on the EU market. The regulation gives no stock-exhaustion period for packaging that does not meet them.
For importers this means the evidence has to exist before the goods are ordered, not after they arrive.
Why moulded fibre is the category to check
Fibre is porous, so grease-resistant moulded fibre needs a barrier. For years the standard barrier was a fluorochemical oil repellent, which is a PFAS. Fluorine-free barriers such as wax emulsions exist, but the two cannot be told apart by looking at the product.
Five documents to request from a bagasse supplier
Ask for all five for the exact grade and colour you intend to buy.
- 01
Total-fluorine test report
On the fibre body, in the grade and colour you are buying. It addresses the 50 ppm limit, which targeted panels alone cannot.
- 02
Targeted PFAS test report
On the same specimen, with the list of substances and the detection limits. It addresses the 25 ppb and 250 ppb limits.
- 03
Specimen identification
A description or photo in the report that ties it to the model, grease barrier grade and colour on your order.
- 04
Grease barrier declaration
A written statement of the barrier chemistry: what is added to the pulp or applied to the surface, and that no fluorochemicals are added.
- 05
Food-contact test report
Migration testing of the fibre body for your market, for example against German BfR Recommendation XXXVI for paper and board.
How to read a PFAS test report
Look at the specimen first
The result applies only to what was tested. A report on a clear lid tells you nothing about the fibre body; a report on a fluorinated grade tells you nothing about the fluorine-free one.
Then the method
A targeted panel finds only the substances on its list. Check which substances were included, the detection limits, and whether polymeric PFAS could be missed.
Then total fluorine
A total-fluorine figure closes the gap left by targeted panels. If it is missing, the 50 ppm limit has not been addressed.
Also check the applicant and manufacturer named on the report: a report issued to another company is not evidence about your supplier's product.
Where Jirun stands against this checklist
Tested
Report RGST25103112005, Nov 2025. Specimen: bagasse tableware body.
- Pentachlorophenol (PCP) content, ISO 15320 — Not detected (MDL 0.1 mg/kg)
- Specific migration of formaldehyde, 3% acetic acid 40 °C 0.5 h — Not detected (MDL 0.1 mg/kg)
Not evidence for the body
The PFAS panel in the same report was run on a transparent pet lid. We do not present it as a PFAS result for bagasse tableware.
Not yet tested
Specimen: Fluorine-free bagasse body (natural + white).
- EN 17681-1:2025 targeted PFAS
- Total fluorine (CIC) for PPWR Art. 5
- BfR XXXVI paper & board package
- 3-MCPD / 1,3-DCP
- MOSH/MOAH (if paraffin wax)
- Fluorescent whitening agents EN 648 (white)
- DIN 10955 sensory
- KIT (TAPPI T559)
- Cobb (ISO 535)
Questions buyers ask
What are the PPWR PFAS limits for food-contact packaging?
Article 5 of Regulation (EU) 2025/40 sets three limits: 25 ppb for any single PFAS measured by targeted analysis, 250 ppb for the sum of PFAS measured by targeted analysis, and 50 ppm for PFAS including polymeric PFAS. Food-contact packaging at or above any of them may not be placed on the EU market.
When did the PPWR PFAS limits start to apply?
On 12 August 2026, the general application date of the PPWR. The limit applies to food-contact packaging placed on the EU market from that date; the regulation gives no period for selling off stock that does not meet it.
Why is moulded fibre packaging checked so closely for PFAS?
Because fluorochemical oil repellents have long been the standard way to make moulded fibre, including bagasse, resist grease. A bagasse product can only be assumed to meet the limits when the supplier shows test results for the fibre body of the grade being bought.
Is there a "PFAS-free" certificate for bagasse tableware?
No. There is no certification scheme that makes a product "certified PFAS-free". The evidence is a set of laboratory reports — total fluorine and targeted PFAS — on an identified specimen, which the buyer should read rather than take as a label.
Does Jirun have a PFAS test report for its bagasse tableware?
Not yet for the bagasse body. Report RGST25103112005 (Nov 2025) contains PFAS results for a transparent pet lid only. The fluorine-free bagasse body has not yet been tested for total fluorine or targeted PFAS; buyers can have it tested to their specification at their own cost.
Do the PPWR PFAS limits apply in the United Kingdom?
No. The PPWR is EU law and does not apply in Great Britain. UK buyers nevertheless commonly ask for the same PFAS documentation, and Jirun supplies only the fluorine-free grade to the UK.
Sources
Related guides
- Fluorine-free, Fluorinated or Laminated Bagasse: Which Grease Barrier Should You Choose?
- How Many Bagasse Containers Fit in a 20GP or 40HQ Container?
- Bagasse vs PLA vs PP vs Paperboard Food Containers: How Do They Compare?
- How Do You Read a Bagasse Tableware Spec Sheet?
- Bagasse Sushi Tray Sizes Explained: No.3 to No.9 and ST-3G to ST-5G
- 5- and 6-Compartment Bagasse Trays for School Meals: Which One to Buy?
- Bagasse Tableware MOQ, Lead Time and Mixed Containers: What Are the Terms?
- How Do You Choose a Bagasse Tableware Manufacturer in China?
- UK Single-Use Plastics Ban: What Is Banned, and Which Bagasse Items Replace It?
- Australia's Plastic Bans by State: Which Takeaway Packaging Is Still Allowed?
- Takeaway Container Sizes: How Big Is a 500, 750 or 1,000 ml Container?