The potential hazards associated with the worldwide presence of per- and polyfluoroalkyl substances, often referred to as PFAS or forever chemicals, should not be ignored. Sara Geeroms, head of the food contact materials department, and Leo Goeyens discuss this issue.

The first alarm cries are more than ten years old

In the joint Madrid declaration from 2015, 14 researchers from various disciplines called for international cooperation towards the reduction of PFAS production and use, as well as the creation of safer alternatives[1].

In the subsequent Zurich Declaration, the authors underscored the need for a unified strategy in conducting additional studies and implementing effective management[2]. They advocated for a holistic approach, emphasising the need to address the entire PFAS family, rather than individual compounds.

The need for immediate action is more urgent than ever, given the verifiable identification of over 14,000 PFAS compounds[3]. However, the true magnitude of the issue may be much greater. According to another article, which appeared at the same time, more than 7 million PFAS are now included in the largest publicly accessible chemical information database, PubChem[4].

High potential for industrial applications is a coin with two sides

PFAS are found in a wide range of products, including packaging, cosmetics, pesticides and kitchenware. A recent study reveals the existence of no less than 68 distinct PFAS molecules in various food contact materials, including paper, plastic, and coated metal[5]. The inconvenient truth is that humans and wildlife are not exposed to one single substance, but rather to a complex mixture of chemicals from various sources, such as food, water, sediments, and soil. We rarely use pure chemicals. Instead, our consumables are typically intricate blends of which we often do not know the exact composition. Unfortunately, this critical factor is too often overlooked in chemical risk assessments and management. Regulatory risk assessments typically focus on individual substances, yet fail to account for the potential harm posed by the complex mixtures to which we are all inevitably exposed[6]. However, we have been aware of that problem for quite some time[7].

Additionally, the strength of carbon-fluorine bonds offers excellent protection against deterioration. This undoubtedly comes with benefits, but we must not underestimate the downside of forever chemicals. Their persistence can be a burden, too. It is crucial to keep this second aspect in mind. Once released, either deliberately or accidentally, into the natural world, these substances can linger for a very long period of time and pollute any environment[8]. The world is currently grappling with the problem of PFAS pollution and its resulting adverse consequences.

Research indicates that PFAS have been found in humans, and it is agreed that they do not belong there. Besides, it has been established that exposure to these compounds is linked to a range of serious health issues. Thyroid disorders and neurological toxicity are prominent examples of this[9].

How does the European Union address the growing body of research on the adverse effects of PFAS use

The European Union (EU) has firmly committed to eliminating all PFAS, with the exception of those deemed necessary, as part of its Sustainable Chemicals Strategy. This strategy is an integral component of the European Green Deal, which is transitioning the EU’s chemical management towards a hazard-based, group-oriented approach.

Regarding packaging, this objective is currently being implemented through two key tools: restrictions under REACH Regulation as well as sector-specific laws, such as the Packaging and Packaging Waste Regulation.

• The Packaging and Packaging Waste Regulation (PPWR, Regulation EU n° 2025/40)[10]: on February 11, 2025, the PPWR came into effect, implementing clear PFAS restrictions for all food packaging placed on the EU market after August 12, 2026.
•  REACH Regulation EC 1907/2006: according to REACH Annexe XVII, certain long-chain PFAS groups, including Perfluorooctanoic acid or PFOA and Perfluorooctanesulfonic acid or PFOS, are already restricted.

The European Chemicals Agency’s Risk Assessment Committee (RAC) and Socio-Economic Analysis Committee (SEAC) are currently examining an EU-wide restriction proposal to ban the manufacturing, placing on the market and use of PFAS as substances and in mixtures and products. This universal PFAS restriction (uPFAS) proposal is the most extensive within the EU, both in terms of the number of chemicals as well as the range of uses covered[11]. The implementation is tentatively set for 2027.

Both the PPWR and the uPFAS restriction proposal include a definition of PFAS that aligns with the definition of PFAS set by OECD[12]: substances containing at least one fully fluorinated methyl (–CF₃) or methylene (–CF₂–) carbon atom, with no H/Cl/Br/I attached to it. However, the PPWR makes some exceptions for molecules with carbonyl or aromatic groups.

The numerical PFAS concentration limits are essentially the same in both frameworks, despite their different scopes and regulatory intents:

•  25 ppb for any individual PFAS substance (except polymeric PFASs),

• 250 ppb for the sum of targeted PFASs, optionally with prior degradation of precursors, and
•  50 ppm for the total PFAS content, including polymeric PFASs.

These concentration limits apply both to intentionally added and unintentionally present PFAS.

An analytical strategy for compliance assessment

Several protocols and methodologies to detect PFAS in different matrices exist, but no single analytical method exists to quantify accurately all PFAS individually. Current methodologies are either:

• screening analyses, focussing on PFAS’s general chemistry, or
• targeted analyses, which can quantify a limited number of individual PFAS molecules.

To ensure consistent measurement of PFAS in food packaging, the EU is creating a unified testing procedure. To this end, the following stepwise approach is recommended to enforce PFAS limits in PPWR[13],[14]:

•  Step 1: total fluorine (TF) quantification. If TF is below 50 ppm, the sample can be considered compliant.

•  Step 2: if TF is above 50 ppm, methods to confirm wether the fluorine is organic (PFAS) or inorganic. If the organic fluorine is below 50 ppm, the sample can be considered compliant.
•  Step 3: check compliance with the 25 ppb (for individual PFAS) and 250 ppb (for sum of PFASs) limits using targeted analysis.

On the basis of the evidence currently available, all samples compliant after step 1, are also compliant with step 2 and 3.

An overview of the most commonly known analytical techniques per step are shown in the diagram below.

(this visual representation is based on sources 13 and 14)

IBE-BVI invests in new infrastructure for total fluorine quantification

In response to the increasing demand from our customers to measure PFAS levels, IBE-BVI is expanding its testing capabilities with Combustion Ion Chromatography (CIC).

The quantification of total fluorine is a relatively fast and cost-effective method to assess the presence of PFAS in a sample.

The process of CIC begins with heating the sample, causing all fluorine to be released and transformed into fluoride ions. These ions are subsequently channelled into an ion chromatograph, where they are separated from other substances and the amount of fluoride is determined. The final outcome provides the total fluorine content of the sample, rather than just one particular fluorinated compound. In essence, it is a two-step procedure: first, burn the sample; then, determine the fluoride output.

CIC’s significant advantage lies in its ability to identify the presence of all fluorine, regardless of which fluorinated compounds may be present. This contrasts with methods that only focus on a few selected compounds, as total fluorine measurements also include any unknown PFAS in the analysis outcome.

This feature is particularly useful for analysing complex samples, such as those made of recycled materials. Furthermore, the sheer number of pollutants makes the time-consuming and costly analysis of each individual substance particularly inadequate in a rapidly changing society. This is all the more true given that the utmost attention must be paid to public health.

Want to learn more about PFAS in packaging? 

Register now for our training course “PFAS in Packaging” on June 16, 2026. During this course, we will take a closer look at PFAS applications, regulations, monitoring and analytical methods for packaging materials.

👉 Information and registration: click HERE

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[1] Blum et al. (2015). The Madrid statement on poly-and perfluoroalkyl substances (PFASs). Environmental health perspectives 123(5), A107

[2] Ritscher et al. (2018). Zürich statement on future actions on per-and polyfluoroalkyl substances (PFASs). Environmental health perspectives 126(8), 084502

[3] Richard et al. (2023). A new CSRML structure-based fingerprint method for profiling and categorizing Per-and Polyfluoroalkyl Substances (PFAS). Chemical Research in Toxicology 36(3), 508-534

[4] Schymanski et al. (2023). Per-and polyfluoroalkyl substances (PFAS) in PubChem: 7 million and growing. Environmental science & technology 57(44), 16918-16928

[5] Phelps et al. (2024). Per-and polyfluoroalkyl substances in food packaging: migration, toxicity, and management strategies. Environmental Science & Technology 58(13), 5670-5684

[6] Backhaus et al. (2025). Include a mixture allocation factor to improve EU chemical risk management. Science, 390(6774), 678-680

[7] CHEMTrust ç2022). The neglected threat of toxic mixtures and how to fix it. https://chemtrust.org/chemicalcocktails

[8] Cousins et al. (2020). The high persistence of PFAS is sufficient for their management as a chemical class. Environmental Science: Processes & Impacts 22(12), 2307-2312

[9] Song et al. (2026). Neurotoxicity and Potential Mechanisms of Exposure to Per-and Polyfluoroalkyl Substances (PFASs). Molecular Neurobiology 63(1), 297

[10] Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste

[11] ECHA (2026); REACH restriction proposal on per- and polyfluoroalkyl substance (PFAS) – questions and answers (https://echa.europa.eu/documents/d/guest/qa_pfas_restriction_process_en)

[12] OECD (2021). “Reconciling Terminology of the Universe of Per- and Polyfluoroalkyl Substances: Recommendations and Practical Guidance.” OECD Series on Risk Management

[13] C(2026) 2151 final, ANNEX to the Communication to the Commission: Approval of the draft Commission Notice on the Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste

[14] Skedung & Bjarnemark. A Harmonized Workflow for PFAS Compliance Testing under EU Packaging and Packaging Waste Regulation and Emerging Universal Restrictions: A Food Contact Packaging Case Study. RISE Research Institutes of Sweden