What Irish Deli & Takeaway Businesses Need to Know About PFAS Packaging Rules
PFAS chemicals, often referred to as "forever chemicals", are now a specific focus of EU packaging regulation, particularly where packaging comes into contact with food.
Since 12 August 2026, the EU Packaging & Packaging Waste Regulation (PPWR) has applied, including restrictions on PFAS in food-contact packaging. Food-contact packaging cannot be placed on the EU market where PFAS concentrations meet or exceed the limits set out in Article 5(5).
What are the PFAS limits?
Article 5(5) of the PPWR establishes three relevant limits:
25 ppb for any individual PFAS, measured using targeted PFAS analysis;
250 ppb for the sum of PFAS measured through targeted analysis, where applicable following degradation of precursors; and
50 ppm for PFAS including polymeric PFAS.
The precise analytical approach can depend on the packaging material and the circumstances. The European Commission's 2026 guidance recommends a stepwise approach beginning with total fluorine screening, followed where necessary by further analysis.
What does this mean for a deli or takeaway?
For a typical food business, the immediate issue isn't necessarily that you need to arrange laboratory testing of every item of packaging yourself.
Instead, you should establish whether the packaging supplier can provide appropriate evidence that the packaging complies with the applicable requirements.
This could include relevant:
supplier declarations;
food-contact compliance statements;
packaging specifications;
PFAS declarations or test evidence; and
other supporting technical documentation.
A generic statement such as "food safe" or a broad supplier assurance may not, on its own, demonstrate compliance with the specific PFAS requirements of the PPWR.
Which packaging should you be thinking about?
The PFAS restriction is specifically concerned with food-contact packaging.
That can include packaging used to contain, protect or serve food where the packaging material comes into contact with the food.
Examples can include:
takeaway containers;
food wrappers;
bakery and deli packaging;
pizza boxes and other food-contact paper or board;
food-contact trays and containers; and
other packaging components that come into contact with food.
The fact that packaging is described as "food grade" or "food safe" does not necessarily answer the separate question of whether it satisfies the PFAS limits under Article 5(5).
What should businesses ask their suppliers for?
If you are buying packaging directly from a supplier, a sensible first step is to ask for documentation that relates specifically to the packaging you are purchasing.
For example:
1. Supplier declaration
Ask whether the supplier has a current declaration addressing PFAS and the applicable PPWR requirements.
2. Packaging specification
Establish exactly what packaging material and construction the declaration relates to.
3. Food-contact compliance information
Where applicable, obtain the relevant food-contact declaration and supporting information.
4. PFAS evidence
Where available, obtain relevant PFAS test results or other technical evidence supporting the supplier's declaration.
5. Product/SKU traceability
Make sure the evidence can be linked to the packaging you are actually purchasing rather than being a generic statement covering an unspecified range of products.
What if my supplier can't provide the information?
This is where the situation can become more difficult.
A supplier may tell you:
"Our packaging is PFAS-free."
That may be useful information, but you should consider what evidence supports the statement and what packaging it actually covers.
If the supplier cannot provide sufficient supporting information, the business may need to consider whether further technical assessment or testing is appropriate.
The Commission's guidance recognises that there is currently no single harmonised EU-level methodology for PFAS testing in food-contact packaging and recommends a stepwise approach to enforcement and assessment.
This means that simply ordering the most extensive possible laboratory test is not necessarily the first or only answer.
A proportionate approach is to establish what evidence already exists, identify the gap, and then determine what additional evidence is actually required.
Why imported packaging deserves particular attention
The issue can become more complicated where packaging or packaged products are:
imported from outside the EU;
sourced through several distributors;
manufactured under an own brand;
supplied by a manufacturer that has limited technical documentation; or
accompanied only by generic or outdated declarations.
The further the business is removed from the original packaging manufacturer, the more important it can become to establish exactly what the available documentation relates to.
What should an Irish SME do now?
If you operate a deli, takeaway, café or other food business, a sensible starting point is to identify the food-contact packaging you currently use.
For each significant packaging type:
1. Identify the supplier
Know who actually supplies the packaging and, where possible, who manufactures it.
2. Identify the material and intended use
Establish what the packaging is made from and whether it comes into direct contact with food.
3. Request current supporting documentation
Ask for relevant food-contact and PFAS documentation rather than relying solely on a generic "food safe" statement.
4. Check that the documentation matches the packaging
A declaration should relate to the packaging you are actually buying and using.
5. Escalate gaps where necessary
If appropriate evidence isn't available, consider whether additional technical assessment or laboratory testing is required.
The key takeaway
For Irish delis, takeaways, cafés and food operators, PFAS compliance doesn't need to become an exercise in understanding complex chemistry.
The practical starting point is much simpler:
Know what food-contact packaging you are using, know who supplies it, and make sure you have appropriate evidence to support its compliance with the applicable requirements.
Where supplier information is incomplete or unclear, the issue should be assessed rather than simply assumed to be compliant.
TrailZero helps Irish SMEs review packaging documentation, identify compliance gaps and establish practical next steps for PPWR and food-contact packaging requirements.
Need help reviewing your packaging documentation? Contact TrailZero for practical packaging compliance support.
