Updated in November 2026: the PPWR has applied since 12 August 2026 and the EU universal restriction has moved forward at ECHA.
TL;DR
- PFAS are thousands of very persistent fluorinated substances, and regulation is tightening fast.
- The real challenge isn’t the law: it’s knowing what is in your raw materials and packaging.
- Customers are already sending PFAS questionnaires; answering needs supplier data you can trace.
- Start with a quick inventory of risky materials and a structured supplier declaration.
1. What is happening with PFAS
- EU universal PFAS restriction. Proposed in 2023 by five countries. ECHA’s Risk Assessment Committee (RAC) adopted its opinion in March 2026, and the Socio-Economic Analysis Committee (SEAC) consulted on its draft opinion until May 2026. SEAC’s final opinion is expected by the end of 2026, followed by a Commission proposal; transition periods and sector derogations are still to be set.
- Food contact packaging. The Packaging and Packaging Waste Regulation (EU) 2025/40, applicable since 12 August 2026, limits PFAS in food contact packaging.
- Existing restrictions such as PFOA and PFHxA in the EU, plus national and state laws in the US.
2. The real story is the supply chain
Few companies add PFAS on purpose. They arrive through raw materials, processing aids, coatings and packaging, often below SDS disclosure thresholds. If you can’t trace it, you can’t declare it.
3. Where PFAS hide
- Raw materials: fluorinated surfactants, polymers, waxes and additives.
- Processing aids: lubricants, release agents, coatings on equipment.
- Packaging: grease- and water-repellent treatments, especially for food contact.
- Impurities: by-products from upstream manufacturing.
4. The cost of doing nothing
Rushed reformulation, blocked shipments, lost tenders and customer audits you can’t pass. PFAS questions are already part of many supplier approval processes.
5. What good PFAS management looks like
- A list of materials at risk, by composition and function.
- A standard supplier declaration on intentionally added PFAS and impurities.
- Composition checked against reference lists, such as the OECD global PFAS database.
- Evidence stored with each raw material, with its date.
- Alerts when regulations or supplier data change.
6. Where to start this week
- Pull the list of raw materials and packaging with fluorinated functions or water/grease repellency.
- Check their composition against a PFAS reference list.
- Send a PFAS declaration request to those suppliers.
- Record what comes back and what is missing.
7. How Kemchain helps
Kemchain Suppliers automates PFAS questionnaires to all your suppliers, uses AI to detect PFAS in safety data sheets and composition, matches them against the OECD PFAS database and ECHA’s registry of restriction intentions, and keeps audit-ready evidence. More in EUDR, PFAS and the Digital Product Passport.
FAQ
Are all PFAS going to be banned in the EU? A broad restriction is under assessment, with derogations and transition periods still to be defined.
Does the PPWR affect me if I don’t make food packaging? Its PFAS limit targets food contact packaging, but your customers in food may ask you for declarations.
Do PFAS appear on the safety data sheet? Not always: they may be below disclosure thresholds or present as impurities.
What should I ask suppliers? Whether PFAS are intentionally added, which ones, at what concentration, and whether impurities are tested.
Updated: 11 November 2026
