PFAS in paper packaging: the EU and US rules buyers must check in 2027

Four PFAS rules that touch paper packaging start within five months of each other: two in the EU in August and October 2026, one in New Mexico on 1 January 2027, and one in the UK's recyclability ratings for 2027.

If your paper packaging touches food, PFAS limits already apply in the EU, and New Mexico bans food packaging with intentionally added PFAS from 1 January 2027. Protective paper that never touches food, such as honeycomb paper wrap around a sealed jar, sits outside those food rules. It does not sit outside the UK's new rating, where any household packaging with more than 1 ppm total PFAS is rated red. In every case the proof is a lab result on your grade, not a "PFAS-free" line on a website.

Checked against official sources on 28 October 2026.

We make honeycomb paper wrap in Jaipur and export it to 20+ countries. We sell it as protective packaging, and our post on whether honeycomb paper can touch food explains why we do not call it food-grade. This post is for buyers who now have to answer PFAS questions about the paper they buy, from us or from anyone else.

Why would paper contain PFAS at all?

Mostly for grease and water resistance. PFAS make paper hold a burger or a bag of pet food without soaking through.

The US Food and Drug Administration said on 28 February 2024 that grease-proofing substances containing PFAS were no longer being sold for US food packaging. Its examples were fast-food wrappers, microwave popcorn bags, take-out paperboard containers and pet food bags.

A plain kraft wrap that protects goods in a box has no use for a grease barrier.

Recycled fibre is the catch. In a 2024 study in Food Additives and Contaminants, Part A, researchers at TU Graz tested raw materials for paper food packaging. They found targeted PFAS only in the recycled material, not in the fresh fibre, and concluded that the contamination mainly happens during recycling. Old greaseproof wrappers can end up in the same bale as everything else.

So "we never add PFAS" and "there is no PFAS in it" are two different sentences. A supplier can honestly say the first and still not know the second.

What does the EU require for food-contact paper?

Since 12 August 2026, Article 5(5) of the Packaging and Packaging Waste Regulation (EU) 2025/40 bars food-contact packaging that contains PFAS at or above these levels:

The Commission's guidance, Notice C/2026/3084 (Official Journal C, 10 June 2026), adds three practical points:

1. Test total fluorine first. Below 50 mg/kg (the same as 50 ppm), the sample can be treated as compliant.
2. There is no sell-off period. Packaging placed on the market after 12 August 2026 must comply.
3. For imports, the moment that counts is release for free circulation in the EU, not the date the goods were made.

There is a second rule just for paper. The REACH restriction on PFHxA, Commission Regulation (EU) 2024/2462, bans it in paper and board food-contact materials from 10 October 2026. The limits are 25 ppb for PFHxA and its salts, and 1,000 ppb for related substances.

Both rules are about food contact. A wrap that cushions a sealed bottle or a boxed cake is not touching the food.

A much wider EU restriction on PFAS in almost every use is still being worked on. It has no adopted date, so I would not plan around any date you read for it.

What changes in the US on 1 January 2027?

At federal level, the FDA announcement above is the main step so far. Outright bans come from the states, and New Mexico's next step is the one with a 2027 date.

The New Mexico Environment Department's page for manufacturers sets out what starts on 1 January 2027 under the PFAS Protection Act:

1. Food packaging with intentionally added PFAS must be removed from sale or distribution in New Mexico.
2. Manufacturers must report each consumer product sold in the state that contains intentionally added PFAS. The initial report costs $2,500.
3. Those products must carry a label: an Erlenmeyer flask with the word "PFAS" inside it. Products made before 1 January 2027 may still be sold without it.
4. Products containing fluoropolymers are exempt from the reporting and the bans, but still need the label.
5. More product groups follow on 1 January 2028, and virtually all non-exempt products by 1 January 2032.

NMED quotes the definition of "intentionally added": a PFAS deliberately added or used during manufacture, whose continued presence in the product is desired or expected.

As I read that, traces that arrive with recycled fibre, which nobody added on purpose and nobody wants, are not intentionally added. That is my reading, not a ruling. If New Mexico matters to your sales, ask NMED or a US lawyer.

New Mexico is not the only US state with PFAS rules. Check each state you sell into, not just this one.

Where does the UK come in?

Through the back door of packaging EPR. This is the rule I would watch most closely if you sell paper cushioning into UK online retail, because it does not care whether the paper touches food.

The RAM 2027 materials assessment guidance (GOV.UK, updated 20 August 2026) rates an item automatically red if it, or any component, contains more than 1 ppm of total PFAS, individually or as a sum. For food packaging the line is 25 ppb.

The same guidance rates packaging red if the producer has no evidence that it deserves amber or green. RAM 2027 covers household packaging supplied from 1 January to 31 December 2027, and red packaging pays a higher disposal fee. Our post on UK EPR fees for paper cushioning in 2027-28 shows what that does to the bill.

Does honeycomb paper wrap contain PFAS?

Here is my honest answer.

Our honeycomb paper wrap is plain kraft paper with cuts in it. It is not a grease-resistant paper, and we do not sell it as one.

But about 99% of what we ship is 100% recycled fibre, and recycled fibre is exactly where the Graz researchers found their traces. So I will not print "PFAS-free" on this page. We hold a heavy-metals test report and an EU declaration of conformity for PPWR. A PFAS figure is a separate lab test, and it is a fair thing to ask any supplier for, including us. Ask us what we hold for your grade before you order.

What should you ask your paper supplier?

Ask for documents you can file. A friendly line in an email will not survive an audit.

1. Is this grade sold for food contact, yes or no? If no, keep it away from unwrapped food.
2. A signed statement that no PFAS is intentionally added, naming the grade and the mill or plant.
3. A total fluorine result from an accredited lab, on the same grade, dated.
4. If the paper touches food in the EU and total fluorine is 50 mg/kg or more, targeted PFAS results, including PFHxA.
5. For UK household packaging, evidence you can keep for seven years to support the RAM rating.
6. Lot numbers on the rolls that match the reports.

What to do before 1 January 2027

1. Sort every paper item you buy into food-contact and not food-contact, market by market. Most protective wrap lands in the second group.
2. If you sell consumer products into New Mexico, check today whether you have a report to file. NMED gives 2 December 2026 as the last day for waiver requests.
3. For UK household packaging, start a RAM file for 2027 now, with the PFAS evidence for each paper item in it.
4. Ask suppliers for their documents in November. A lab test takes time to book and run, and January is the wrong month to discover a gap.
5. Keep honeycomb wrap outside the food-contact layer. Bag or wrap the food in something documented for food first.

If you need a paper cushioning quote with the documents listed out before the price, write to us through our contact page. Tell us your markets and whether anything in the box is unwrapped food, and we will tell you plainly what we can document.