12
PFAS restriction effective date
50%
Empty space ratio cap effective 1 January 2030
25
PFAS individual limit by targeted analysis from 12 August 2026
Key takeaways
- Since 12 August 2026, PFAS in food-contact packaging is banned above strict limits for EU market access.
- The PFAS thresholds include 25 ppb for individual PFAS, 250 ppb total PFAS (excluding polymeric), and 50 ppm total including polymeric PFAS.
- Empty space caps, recyclability by design, and recycled content requirements only become mandatory from 1 January 2030.
- Amazon enforces EU packaging laws downstream, meaning sellers must be ready with compliance documents before being asked.
- Generic food-grade certificates do not satisfy the PFAS declaration requirement under Regulation (EU) 2025/40.
The PPWR requirements for online sellers 2026 are simpler than the noise around them. Regulation (EU) 2025/40 started applying on 12 August 2026, and on that date exactly one substantive restriction became binding for most Amazon sellers: per- and polyfluoroalkyl substances in food-contact packaging. Everything else in the headlines - the empty space cap, recycled content, recyclability by design - has a date, and that date is 1 January 2030.
This matters because the two get sold together. A seller who spends September re-engineering carton fill is solving a 2030 problem. A seller shipping food in a greaseproof wrapper is sitting on a today problem.
What the PPWR requires from sellers right now
The European Commission confirmed on 11 August 2026 that food-contact packaging containing PFAS above strict limits can no longer be placed on the EU market. The Commission names the formats explicitly: takeaway containers, fast-food wrappers, microwave popcorn bags, bakery paper, pizza boxes.
That is a market-access rule, not a labelling rule. It does not care whether the packaging is your product or the box your product ships in. If the food touches it and it is sold into the EU, it is in scope.
The legal text is Regulation (EU) 2025/40, adopted 19 December 2024 and published in the Official Journal on 22 January 2025. It repeals Directive 94/62/EC, which is why national packaging rules a seller learned five years ago are no longer the whole picture.
The PFAS limits in Regulation (EU) 2025/40, in numbers
The Food Packaging Forum sets out the thresholds that apply from 12 August 2026:
- 25 parts per billion for any individual PFAS by targeted analysis, excluding polymeric PFAS
- 250 parts per billion for the sum of PFAS by targeted analysis, excluding polymeric PFAS
- 50 parts per million for total PFAS, including polymeric PFAS
Two details decide whether this reaches you. First, the limits apply to concentration in the packaging material itself, not migration into the food - so a supplier certificate about migration testing does not answer the question. Second, the restriction covers both intentionally and non-intentionally added PFAS. Grease resistance is the usual reason it is there at all, and a supplier who never mentioned PFAS may still be using it.
What PPWR compliance does not require yet
The rules generating the most consultancy traffic are not in force. Latham and Watkins puts the PPWR application timeline as follows:
- 1 January 2030: the empty space ratio cap of 50% for grouped, transport and e-commerce packaging; recyclability design requirements; minimum recycled content; packaging minimisation
- 12 August 2028 or later: harmonised packaging labelling, running from the later of that date or 24 months after the implementing acts
- Extended producer responsibility financial contributions: 18 months after the relevant delegated and implementing acts enter into force
You will see the empty space rule quoted as a 2026 obligation, sometimes at 40%, sometimes at 50%. It is 50%, and it is 2030. Build toward it, do not panic-buy carton sizes for it in Q4.
How this reaches an Amazon listing
Amazon does not write EU packaging law, but it enforces it downstream. The pattern across GPSR and packaging EPR has been consistent: the regulator sets a date, the marketplace starts asking for documents some months later, and listings without documents stop selling. Sellers who wait for the Seller Central email are always working against a shorter clock than the one the regulation gave them.
So the practical question is not whether Amazon has asked yet. It is whether you could answer if it did.
What to do this week
Ask every supplier of food-contact packaging for a PFAS statement against the three thresholds above, in writing, referencing Regulation (EU) 2025/40. A generic food-grade certificate is not that statement.
If a component has to change, price the change against the calendar and not just the unit cost. A new carton spec means new dimensions and new weight, and both land straight in your fulfilment cost - which is already moving, because the holiday peak fulfilment fees that run from 15 October are priced on the ship date. Changing packaging in October costs more than changing it in September for reasons that have nothing to do with the packaging, as the peak season deadline that costs more than the surcharge sets out.
And leave the 2030 rules for 2030. There is a real deadline in the PPWR this quarter, and it is not the one most people are talking about.
Sources
- Comision Europea - New EU rules on packaging enter into application environment.ec.europa.eu
- EUR-Lex - Reglamento (UE) 2025/40 eur-lex.europa.eu
- Food Packaging Forum - PPWR PFAS limits apply from August 12 foodpackagingforum.org
- Latham & Watkins - European Packaging and Packaging Waste Regulation: summary of provisions and new guidance lw.com
Hey! I'm Amara
Press at SellerKey.co
☕ Espresso. Never a latte macchiato.
I cover Amazon fee and policy changes: what changed, when it applies and where Amazon published it.
