A recent PFAS story from Europe has attracted wide attention.
In the “Chemical Valley” south of Lyon, France, 192 residents have sued Arkema and Daikin Chemical France, claiming more than EUR 36 million. Several public reports describe it as one of the most representative PFAS civil lawsuits in Europe.
Many companies’ first reaction to such news is: “This is a chemical pollution case – it has little to do with our packaging, exports or products.”
But that judgment is becoming increasingly dangerous. PFAS risk is moving from “environmental controversy” to “regulatory requirement”, and from “pollution incident” to “market access issue”.
PFAS – per- and polyfluoroalkyl substances – are widely used in packaging coatings, grease-resistant treatments, membrane materials, seals, electronic components and industrial additives because they are water-, oil-, heat- and corrosion-resistant.
But their defining feature is also their biggest problem: they are extremely difficult to degrade.
Official EU information states that PFAS are highly persistent substances whose use in food contact materials and packaging poses clear human exposure risks, and therefore need to be restricted in packaging legislation. The European Commission also says that if current levels of PFAS pollution continue until 2050, the related social costs could reach EUR 440 billion.
So the PFAS issue has never been just “will it exceed limits” but rather that once PFAS enter the environment, supply chains and products, the subsequent costs of remediation, substitution, claims and customer scrutiny can be very high.
The real change: PFAS are now in packaging regulations
Many companies still think of PFAS as “some lawsuits in Europe and the US” and “likely to get stricter in future”.
But the more practical point is: it’s not the future – it’s now.
EU: the PPWR has written PFAS into its requirements
The EU PPWR, Regulation (EU) 2025/40, entered into force on 11 February 2025 and applies generally from 12 August 2026. The European Commission website states clearly that PFAS in packaging will be banned from August 2026.
According to the official text on EUR-Lex, from 12 August 2026 food contact packaging containing PFAS at or above the legal limits may not be placed on the EU market. The regulation sets three specific thresholds:
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25 ppb: targeted analysis limit for any individual PFAS
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250 ppb: targeted analysis limit for the sum of PFAS
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50 ppm: limit for total PFAS, including polymeric PFAS
This means that for packaging companies exporting to the EU, PFAS are no longer an “upstream chemical issue” but a real packaging market access requirement.
US: beyond the EPA, look at TPCH and state packaging laws
The US is more easily misunderstood.
When US PFAS regulation comes up, many companies think only of the EPA. But for packaging-related companies, the TPCH route deserves equal attention.
TPCH stands for the Toxics in Packaging Clearinghouse.
The Model Toxics in Packaging Legislation it promotes is not a uniform federal law but a model framework for state laws. In its 2021 update, TPCH added PFAS and phthalates to the substances regulated in packaging.
An important compliance point: TPCH is not a federal law automatically applicable across the US. According to NEWMOA and TPCH, states must adopt all or part of the model legislation for it to become enforceable in that state; and so far no state has adopted the 2021 update “wholesale” – most have adopted parts of it.
But that doesn’t mean companies can ignore it.
TPCH also tracks related state legislation. Its “Related State Laws” page shows that Connecticut and other states have explicitly restricted PFAS in food packaging.
In other words, the reality of US packaging PFAS compliance is not “one national law” but the TPCH model law + separate action by individual states.
This also means that companies selling in the US cannot just ask “is there a uniform US requirement?” but must ask further: “does my target state restrict PFAS in packaging?”
Which companies should be most alert now?
If your business involves the following, we recommend paying attention soon:
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Paper packaging, grease-resistant paper, paper cups, cartons, coated paper
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Laminated films, barrier layers, surface treatments
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Packaging materials, auxiliary materials, additives
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Brand owners and traders exporting to the EU and US
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Packaging supply chains for medical, food, personal care and consumer products
Because many PFAS are not added “deliberately” but may be hidden in:
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Grease- and water-resistant coatings
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Upstream raw material systems
The most dangerous situation is not “finding PFAS” but when the customer asks, the regulation is in force and the goods are about to ship, and the company still doesn’t know whether its packaging contains PFAS.
What can companies do now?
We recommend four things first:
First, identify the product scope: which packaging is for food contact, and which materials, processes and components carry PFAS risk.
Second, investigate the supply chain: collect material composition, fluorine declarations, use descriptions and compliance commitments from suppliers.
Third, carry out technical confirmation or testing where needed, prioritizing high-risk materials, key projects and core raw materials.
Fourth, prepare strategies by market: in the EU, focus on the PPWR; in the US, assess according to the TPCH model law and target-state requirements.
What customers will care about most is often not you saying “there should be no problem”, but whether you can provide evidence that you have identified, checked and managed the issue.
Final thoughts: PFAS may be the watershed for the next round of packaging compliance
The biggest reminder from the EUR 36 million claim in France is not just that PFAS are harmful, but that the social, legal and commercial costs of PFAS are rising at the same time.
The EU PPWR has written PFAS into packaging law; the US is steadily pushing PFAS into packaging compliance through the TPCH model law and state laws.
In the news it looks like a pollution incident. But for companies it may quickly become an order issue, a customer issue, an export issue or even a liability issue. Those who identify it first will be more proactive; those who wait for customers to ask are more likely to be caught on the back foot.
How Can EVERBIZ Support Companies?
Around PFAS + packaging compliance + EU/US market requirements, EVERBIZ can help companies with:
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EU PPWR applicability analysis: whether packaging products are affected by the PPWR, and the boundaries of requirements on PFAS, food contact packaging, etc.
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Initial identification of US TPCH/state packaging laws: based on target sales states, whether PFAS packaging restrictions apply.
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Initial PFAS risk screening: risk identification for packaging materials, coatings, auxiliary materials and laminated layers.
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Supply chain declarations and documentation: helping establish material declarations, supplier surveys, customer response logic and basic compliance records.
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Testing and remediation advice: verification, substitution and remediation directions for high-risk items.
If your products involve packaging, food contact materials, paper products, coatings or composite materials, or you plan to export to the EU or US, now is the time to start paying attention to PFAS compliance,
as it is likely to become a key issue in the next round of packaging exports and customer audits.
Follow EVERBIZ for more practical insights into EU/US product compliance, packaging regulations, chemical restrictions and export requirements for medical and industrial products.
EVERBIZ Certification Services (Shanghai) Co., Ltd. (EVERBIZ) is a professional compliance service platform for testing, certification, consulting and training of medical products, dedicated to helping leading medical R&D companies at home and abroad improve their compliance capabilities and competitiveness. The company has offices and branches in Shanghai (China), Hong Kong, Munich (Germany), Salzburg (Austria) and Thailand, covering nearly 25 industries of compliance products (such as medical devices, new energy, household appliances, lighting, tools, laboratory instruments, machinery, in vitro diagnostics, wireless products and reagents).
Shanghai: Room 909, Building 1, Lane 111 Luxiang Road, Baoshan District, Shanghai, China; Germany: Landsberger Str. 155, 80687 München, Germany
Austria: Innsbrucker Bundesstraße 136/3, 5020 Salzburg, Austria
Hong Kong: Room A1, 11/F Winner Building, 36 Man Yue Street, Hung Hom, Kowloon, Hong Kong
Thailand: No. 850 Soi Lat Krabang 30/5, Lat Krabang Subdistrict, Bangkok 10520
