Development of a Risk Matrix for Assessing PFAS in Food Packaging

The minimisation of substances of concern in packaging is a key objective of the European Union's Packaging and Packaging Waste Regulation (PPWR), complementing existing legislation governing the safety of food contact materials. Per- and polyfluoroalkyl substances (PFAS) present particular challenges due to their persistence, chemical diversity, and documented use in certain food contact materials. Article 5 of the PPWR requires packaging to be designed and manufactured to minimise such substances throughout the life cycle. This study develops a structured, material-based PFAS risk matrix to support compliance screening for food packaging under Article 5. The approach combines scientific evidence on PFAS occurrence, functional applications, and analytical detection with material classification systems used in recyclability assessments. Packaging materials are categorised by their likelihood of PFAS relevance, enabling proportionate prioritisation of efforts. Application of the matrix shows that fibre-based materials with grease- or water-resistant treatments exhibit higher relevance than glass, untreated paper, or polyethylene terephthalate (PET). The framework also clarifies the role of total fluorine (TF) and extractable organic fluorine (EOF) as supportive, material-specific indicators rather than standalone compliance metrics. By integrating PFAS considerations into design, sourcing, and portfolio management, the framework promotes proactive chemical risk governance aligned with circular economy objectives.