Long before concerns for environmental impact emerged, per- and polyfluoroalkyl substances (PFAS) have played a major role across the global industry. Also referred to as the “forever chemicals”, these synthetic substances have been a part of the manufacturing processes since the 1940’s. However, with the development in science and technology, we now have evidence that many PFAS are highly persistent in the environment and the exposure to certain PFAS has been linked to adverse environmental and human health effects, and alternatives are increasingly becoming available for many packaging applications. The European Union has now decided to move towards a total phase-out, and with that the packaging industry is facing an urgent challenge: How to adapt to these PFAS regulations while maintaining a circular economy?
What are PFAS and Why are they a Problem?
PFAS (per- and polyfluoroalkyl substances) is not a single substance but a family of overall 10,000 synthetic chemicals. These forever chemicals have a strong ability to resist heat, water, and oil, and this strength comes from the carbon-fluorine bond, which is one of the strongest known chemical bonds, making these substances durable.
Sounds impressive…where is the problem then?
The durability of these synthetic substances comes at a significant cost. PFAS are extremely resistant to natural degradation, which means that once they are released into the environment, they stay there longer than we can imagine and contaminate water, soil, and wildlife. And it doesn’t stop there. Persisting in the environment for decades, they can also accumulate in our bodies leading to serious health concerns, including hormonal disruption, immune system suppression, and an increased risk of certain cancers. In Europe alone, health issues from PFAS exposure are estimated to cost society between €52 billion and €84 billion every year, and without decisive action the cumulative social and healthcare costs could surpass an even larger amount. So, now you see the problem!
Source: https://www.istockphoto.com/
Regulations on PFAS in The EU including Italy
The European Union’s Packaging and Packaging Waste Regulations (PPWR) deadline is August 12, 2026, with which there will be a shift from ‘recommendation’ to ‘enforced prohibition’. PPWR introduces a definitive ban on PFAS in food-contact packaging. Therefore, after the deadline any food-contact packaging exceeding the mentioned limit will be banned from the market:
- 25 ppb for individual substances
- 250 ppb for the sum of substances
- 50 ppm for total PFAS
The most challenging part of the ban is that there is no transition period for the existing stock. Any packaging containing PFAS above these limits that remains in the warehouse after August 12, 2026, will effectively become an “asset loss” for the company. Another framework, REACH, is evaluating a total restriction on approximately 10,000 PFAS and the final decision is expected between 2027 and 2028, while the European Chemicals Agency (ECHA) committees are debating potential 5 to 12 years exemptions for strictly “essential” uses. Additionally, the POPs Regulation continues its limits on PFAS and from October 10, 2026, with further its restriction on a PFAS compound PFHxA (and its related substances) for specific consumer goods like cosmetics, textiles, and food packaging.
For the Italian market, where the paper recycling rate is around 85%, these regulations present a specific challenge in cross-contamination, meaning the “legacy” PFAS that have accumulated in recycled paper fibers over decades. When the EU is providing the regulatory framework, Italian companies need ‘industrial intelligence’ to map their supply chains and collaborate with mills to ensure that the recycled streams remain clean.
By following the principle of Extended Producer Responsibility (EPR), the EU is now holding procedures financially accountable for the entire life cycle of the packaging. PFAS-free materials may help companies improve recyclability, reduce future compliance, and waste management risks under evolving EPR schemes. An important economic check for companies is that while the removal is expensive (up to $18 million to remove just one pound of PFAS from water), the cost of failing to act is far higher when accounting for the total healthcare burden of €52 – €84 billion annually. Therefore, your decision must be smart and thoughtful!
The Impact on the Packaging Industry
PFAS regulations are a complex challenge for the packaging industry, especially for those working with recycled paper. This is because of the “legacy” contamination trap. PFAS can enter the packaging cycle through “cross-contamination”, which means that recycled paper may contain traces of substances used in entirely different industries decades ago. Identifying these traces requires ‘industrial intelligence’ because many manufacturers do not have direct links to the original paper mills.
Economic & Operational Impacts:
- R&D and Testing: Companies need to invest in frequent lab analysis and new materials, such as vegetal waxes or specific polymers, which may increase production costs by 10% to 30% in the short term.
- The EPR Principle: Under the Extended Producer Responsibility (EPR), producers are responsible for the entire life cycle of their packaging. If your packaging contaminates a recycling stream, it could lead to increased “eco-modulated” taxes or heavy fines.
- Transparency: The industry is expected to shift from simple manufacturing to a model of radical transparency and using technologies like the Digital Product Passport or iQRcodes is required to make data on origin and composition accessible.
- Circularity Paradox: Even with circular solutions, companies now need to provide consultancy to their clients to explain that true circularity requires a critical, analytical view of what enters the production cycle.
- Financial Risk: While the substances themselves are cheap to buy, the cost to remove them from wastewater can reach $2.7 to $18 million per pound. Investing in “PFAS-free” solutions at the source is the only way to avoid these long-term financial liabilities and the massive healthcare burden on society.
How should Companies Adapt?
The strategy required to cope with these regulations and adapt the changes is resilience and transparency. Instead of just relying on generic certifications, companies must classify materials by the level of risk and give priority to suppliers who provide full transparency on the origin of recycled fibers. Furthermore, companies must adopt tools like iQRcodes and the Digital Product Passport to provide transparency regarding material origin, composition, and end-of-life instructions.
BOTTA EcoPackaging is emphasizing on these challenges, and we believe that the solution needs a collaborative dialogue between suppliers, converters, and distributors to ensure that the circular economy remains truly clean, and the industry successfully adapts to these regulations without the burden of penalties.
