Risk-Based Assessment of PFAS in Food Contact Packaging Using Packaging Component and Supplier Risk Indicators

The implementation of PFAS restrictions under the Packaging and Packaging Waste Regulation (PPWR) in Europe requires manufacturers, retailers, and packaging suppliers to assess large numbers of food contact packaging materials within short timeframes. As comprehensive analytical testing of all packaging components is not feasible, risk-based approaches are needed to prioritise testing and compliance efforts.

This study builds on a previously published PFAS risk assessment methodology (Wack et al., 2026; Foods 15, 1183) and extends it by integrating supplier-based risk indicators, a generic analytical testing strategy, and an updated risk ranking of packaging components. The approach was applied to a dataset of commercial food packaging systems covering different materials, formats, and  components.

Packaging components were classified into risk categories based on PFAS-related applications, functional requirements, material composition, and manufacturing processes. Supplier-related indicators included compliance documentation, PFAS declarations, analytical data, supply-chain transparency, geographical sourcing, and previous compliance information. A tiered testing strategy aligned with European Commission principles links risk categories to verification levels ranging from documentation review to targeted PFAS analysis, total fluorine screening, and confirmatory testing, ensuring prioritisation of high-risk systems.

The results demonstrate that PFAS-related risks in packaging systems are influenced by both material-specific characteristics and supply-chain-related factors. Significant differences in PFAS risk potential were identified among packaging components, with the highest risk categories associated with recycled materials, grease-resistant and barrier-treated paper and board materials or coatings and selected functional additives. However, a purely material-based classification is insufficient to fully capture the overall PFAS risk of a packaging system. While material properties and intended applications provide important indicators of potential PFAS relevance, the actual risk is also influenced by raw material origin and composition, manufacturing processes, use of additives and processing aids, and implemented quality control measures. Supplier- and supply-chain-related information therefore represents a critical complementary dimension, as differences in transparency, compliance documentation, PFAS declarations, analytical data, and material traceability can lead to different risk profiles for comparable materials.

Overall, the findings demonstrate that combining material- and supplier-specific information improves the identification of packaging systems requiring analytical verification and supports efficient PFAS risk management under PPWR through prioritised testing and targeted resource allocation.