EU PPWR PFAS Rules for Baking Paper Importers: Compliance Checklist

Direct answer: Regulation (EU) 2025/40 applies from 12 August 2026. Article 5 restricts food-contact packaging containing PFAS at or above specified concentration limits. Importers should confirm product scope, obtain appropriate evidence for the finished packaging, and agree documentation responsibilities with qualified legal advisers, accredited laboratories and suppliers.

What does Regulation (EU) 2025/40 say about PFAS?

Article 5(5) states that, from 12 August 2026, food-contact packaging must not be placed on the market when it contains PFAS at or above the regulation’s concentration limits. The limits are expressed for individual targeted PFAS, the sum of targeted PFAS and PFAS measured through total organic fluorine. The wording is “equal to or above,” so the legal threshold should not be rewritten as a simple “less than or equal to” pass claim.

• 25 ppb: any PFAS measured with targeted analysis, excluding polymeric PFAS.
• 250 ppb: the sum of PFAS measured as the sum of targeted PFAS analysis, with precursor degradation where applicable, excluding polymeric PFAS.
• 50 ppm: PFAS, including polymeric PFAS; the regulation also addresses evidence where total fluorine exceeds this level.

These figures are legal concentration limits, not a complete laboratory protocol. Sampling, extraction, analyte lists, limits of quantification, precursor treatment and interpretation should be agreed with an accredited laboratory for the actual paper, coating, ink, adhesive and packaging construction.

Which products and transactions need review?

The restriction concerns food-contact packaging placed on the EU market. Whether a specific roll, sheet, liner or converted article is “packaging,” when it is legally placed on the market, and which economic operator carries each obligation depend on the product and supply chain. Do not rely on this article to decide treatment of existing inventory, goods in transit or a specific customs entry.

Importers should document the product format, intended food-contact use, coating, printing, adhesives, batch identification, manufacturer, importer and date of placing on the market. A legal adviser can then determine scope using the official regulation and relevant EU or national guidance.

What evidence should an importer request?

No single certificate automatically proves compliance for every product. A defensible file normally connects the tested sample to the finished packaging and explains why the selected method is suitable.

1. Product identity: SKU, dimensions, basis weight, coating, printing, adhesives, production site and batch or lot reference.
2. Supply-chain declarations: statements covering relevant pulp, coatings, additives, inks and adhesives, with the issuer and date clearly identified.
3. Laboratory evidence: a report from a suitably accredited laboratory describing the sample, method, analyte scope, reporting limits, results and measurement uncertainty where applicable.
4. Regulatory assessment: written confirmation from the responsible economic operator explaining how the evidence supports Article 5 compliance for the finished packaging.
5. Change control: a process for reassessment when raw materials, formulations, suppliers, production locations or packaging construction change.

Specific methods such as ASTM, EN, EPA-derived or laboratory-developed procedures may be proposed, but this page does not designate one method as universally mandatory. Ask the laboratory to justify fitness for the substrate and the regulatory question.

Importer compliance checklist

Questions to ask a baking paper supplier

• Can you identify the exact production batch and all relevant coating, ink and adhesive systems?
• Which parts of the evidence relate to raw materials, and which relate to the finished packaging?
• Which laboratory performed the work, what accreditation applies, and what was the reporting limit?
• How will you notify us if a formulation, raw-material supplier or production site changes?
• Who is responsible for preparing the final regulatory assessment for the EU market?

A supplier’s commercial statement can support due diligence, but it does not replace the importer’s legal obligations or an appropriately scoped test report. Buyers can review Runjia’s baking paper manufacturing capabilities separately from the regulatory assessment.

Testing and legal interpretation boundaries

This page does not claim that a named laboratory, price, turnaround time or test method is required by Regulation (EU) 2025/40. It also makes no claim about routine declaration issuance, formulation changes, testing of every Runjia SKU or guaranteed customs treatment. Those statements require current, product-specific records and should only be made alongside evidence.

For a purchasing decision, request the actual report and verify its sample identity, date, scope and issuing laboratory. For a legal decision, use the official text and obtain advice for the relevant Member State, transaction and economic operator.

Official source

Regulation (EU) 2025/40 on packaging and packaging waste — EUR-Lex official text.

Disclaimer

This page provides general sourcing and compliance information, not legal advice, conformity certification or a laboratory opinion. Rules and guidance may change. Verify the current official text and obtain qualified advice before placing food-contact packaging on the EU market.