Regulatory Updates on PFAS, Recyclable Packaging, and Microplastics
CHEMICAL TRADING VIETNAM – 2026 June
I. PFAS Regulation (Effective 12 August 2026)
What is PFAS?
PFAS stands for Per- and Polyfluoroalkyl Substances. They are a massive group of over 10,000 man-made chemicals widely used since the 1940s.
PFAS contain a carbon-fluorine bond—one of the strongest chemical bonds in organic chemistry. Because of this structure, they are incredibly effective at repelling water, grease, and oil, while resisting extreme heat. You can find them in everyday items like non-stick cookware, water-resistant clothing, food wrappers, makeup, cosmetics, electronics, and firefighting foams.
Why are they a problem?
- “Forever Chemicals”: They do not break down naturally in the environment, leading to massive accumulation in soil and water.
- Bioaccumulation: They build up over time inside human bodies and wildlife.
- Health Risks: Exposure to certain PFAS has been linked to liver damage, thyroid disease, obesity, fertility issues, immune system suppression, and increased risks of cancer.
Latest PFAS Regulations in the EU
The European Union is executing the most aggressive crackdown on PFAS in history. Instead of banning these chemicals one by one, the EU is shifting toward a class-based ban targeting virtually all PFAS as a whole.
The PPWR (Packaging and Packaging Waste Regulation) establishes a strict ban on intentionally added PFAS in food-contact packaging across the EU, with no grandfathering provisions for existing stock.
Key Deadlines & Timeline
- 11 February 2025: Entry into force of the PPWR.
- 12 August 2026: Mandatory compliance date. All food-contact packaging placed on the EU market must meet strict threshold limits regardless of its manufacturing date.
Concentration Threshold Limits
Packaging compliance is measured against three specific concentration limits:
- Individual non-polymeric PFAS: Limit of 25 ppb (parts per billion).
- Sum of non-polymeric PFAS: Limit of 250 ppb.
- Total PFAS (including polymeric PFAS): Limit of 50 ppm (parts per million).
Crucial Risk Note: Because there is no inventory clearance/grandfathering window, any pre-manufactured stock exceeding these limits becomes immediately unsaleable on the EU market after 12 August 2026.
Immediate Sector-Specific Bans
While the massive REACH blanket ban undergoes finalization, several product-specific laws are hitting the market right now:
- Food Packaging (August 2026): Starting August 12, 2026, strict PFAS limits will enter into force across the EU for all food contact packaging (such as fast-food wrappers and microwave popcorn bags) under the Packaging and Packaging Waste Regulation (PPWR).
- Toy Safety Regulation: Formally adopted in late 2025 and having entered into force on January 1, 2026, this regulation bans hazardous chemicals—explicitly calling out PFAS—from being used in children’s toys (with compliance required by 2030).
- National Restrictions: Individual member states are fast-tracking their own bans ahead of the EU. For instance, France enacted a law banning the manufacturing and sale of PFAS in consumer products like cosmetics and ski waxes starting January 1, 2026. Both France and Denmark are expanding bans to consumer textiles and waterproofing agents later this year.
- Water and Soil Monitoring: In April 2026, the EU updated its water pollutant lists and Soil Monitoring Laws to require member states to actively measure, trace, and establish strict contamination limits for PFAS hotspots.
Supply Chain Impact: Polymer Processing Aids (PPAs)
Historically, polyolefin manufacturers (PE/PP) have used fluoropolymer-based Polymer Processing Aids (PPAs) to eliminate melt fracture, prevent “sharkskin” defects, and improve extrusion throughput.
- The Polymeric PFAS Trap: Even though fluoropolymer PPAs are stable polymers, they are chemically classified as polymeric PFAS. They easily trigger or exceed the 50 ppm total PFAS/fluorine threshold if intentionally added.
- New solution: PFAS-free processing aid additives
II. Recyclable Packaging Regulations
This framework is split into Design for Recycling (DfR) performance grades and mandatory recycled content thresholds.
1. Recyclability Performance Grades & Timeline Ladder
From 2030, all packaging placed on the market must be designed for recycling and will be graded on a scale from A to C based on its Design for Recycling (DfR) score. Anything scoring below Grade C is banned.
- 1 January 2030: Packaging must achieve at least Grade C to maintain market access.
- 1 January 2035: Introducing “Recycled at Scale” rules. Packaging must prove it is widely collected, sorted, and recycled in real-world infrastructure.
- 1 January 2038: The performance ladder tightens. Packaging must step up to at least Grade B to remain on the market.
| Recyclability Grade | Performance Score Threshold | Market Access Window |
| Grade A (Highest performance) | ≥ 95% | Allowed indefinitely |
| Grade B (Good performance) | ≥ 80% | Allowed indefinitely |
| Grade C (Minimum compliance) | ≥ 70% | Allowed from 2030; Banned from 2038 onward |
| Below Grade C (Non-recyclable) | < 70% | Banned from 1 January 2030 |
2. Recycled Content Minimums & Exemptions
The regulation mandates that plastic packaging components include minimum percentages of post-consumer recycled (PCR) plastic by 2030, with a massive step-up target by 2040 (e.g., targets rising up to 50%–65% depending on the format and contact sensitivity).
- 2030 Target Examples: 30% for contact-sensitive PET packaging (excluding beverage bottles); 10% to 35% for other plastic packaging formats.
- Exemptions & Derogations: The regulation grants specific exclusions from mandatory recycled content requirements for sensitive applications, including:
- Contact-sensitive packaging for infant formula and follow-on formula.
- Processed cereal-based food and baby food.
- Food for special medical purposes.
- Packaging for medical devices and advanced therapies.
- Outer packaging for dangerous goods (ADR).
III. Microplastics
- Regulatory Status: There are currently no direct bans or restrictive thresholds for microplastics defined under the PPWR packaging design rules.
- Current Focus: Activities remain centered around data transparency, sharing harmonized scientific facts, and standardizing advanced testing/reporting methodologies across supply chains.
Standardization of Testing Methods
Because data cannot be regulated without standardized metrics, the current EU mandate focuses on developing universally recognized testing methods:
- Dynamic Fragmentation Testing: Simulating environmental weathering (UV exposure, physical abrasion) on packaging materials to measure how fast they degrade into micro- and nano-plastics.
- Analytical Standardization: Aligning the industry on analytical tools to count microparticles in food and water matrices. The primary standardized methodologies utilize:
- FTIR (Micro-Fourier Transform Infrared Spectroscopy)
- Raman Spectroscopy
- Pyrolysis-GC-MS (Gas Chromatography-Mass Spectrometry)
