If your napkins reach the EU, a regulation that took force on 12 August 2026 now governs the substances in them. Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation (PPWR) — replaced the old 1994 directive and applies directly in all 27 member states with no national transposition. For paper and tissue food-contact packaging, the headline constraint is PFAS. This is the buyer-facing rulebook.
The PFAS Thresholds That Now Apply
For food-contact packaging placed on the EU market, PFAS is limited at three levels. Any one being met or exceeded blocks sale:
| Measure | Limit | Note |
|---|---|---|
| Single PFAS substance | ≤ 25 ppb | Targeted analysis; polymeric PFAS excluded from the count |
| Sum of targeted PFAS | ≤ 250 ppb | Measured after precursor degradation |
| Total fluorine (incl. polymeric PFAS) | ≤ 50 ppm | Above 50 mg/kg → must prove fluorine source |
Crucially, the limit is on PFAS content in the material — not migration into food. So PFAS brought in by a grease-resistant coating, adhesive, or even ink counts. Heavy metals (lead, cadmium, mercury, hexavalent chromium) are also capped at 100 mg/kg overall.
No Grandfathering — Read That Twice
The rule has no stock消化 period. Napkins you manufactured before 12 August 2026 can keep selling only if they were already placed on the EU market before that date. Stock produced earlier but first placed on the market after 12 August must comply. In practice: a container that clears customs after the deadline is judged by the new limits, not the production date.
What This Means for Napkin Importers
- Treat "PFAS-free" as a documented claim, not a label. A self-declaration no longer satisfies the requirement; accredited lab data tied to the specific product does.
- PFAS usually enters through the grease-resistant treatment. Plain, uncoated napkins are the easiest to clear; printed or treated ones need coating disclosure.
- Plan to the strictest applicable market. An item legal in one US state can fail another’s total-fluorine trigger — and the EU limit is now among the strictest.
- Keep the technical file. Single-use packaging compliance documentation is retained for years and must be producible on request.
Documents to Request From Your Supplier
| Ask for | Why it matters |
|---|---|
| PFAS / total-fluorine lab report | Proves the 25/250 ppb and 50 ppm limits are met |
| Coating & additive disclosure | Shows whether grease resistance comes from PFAS |
| Food-contact declaration | Links to food-safety compliance → |
| Heavy-metals test (≤100 mg/kg) | Required under PPWR substance limits |
Key Takeaways
- EU PPWR (2025/40) applies from 12 August 2026, directly in all 27 states.
- PFAS limits: 25 ppb single / 250 ppb sum / 50 ppm total fluorine — on content, not migration.
- No grandfathering: post-deadline placement requires compliance regardless of production date.
- Collect accredited lab reports and coating disclosures; a badge image is not enough.
Building an EU-Compliant Order?
We provide PFAS / total-fluorine lab reports, coating disclosures, and food-contact statements with every EU-bound quotation.
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