PFAS in Food Packaging: Greaseproof Paper, Moulded Fibre and the Thresholds at Work

The Article 5 PFAS thresholds (25 ppb any individual PFAS, 250 ppb for the sum excluding polymeric PFAS, 50 ppm total including polymeric) apply to food-contact packaging from the general application date, and the sector's exposure concentrates where grease resistance was historically bought with fluorinated chemistry: greaseproof papers and boards (burger wraps, bakery bags, pizza boxes' liners), moulded fibre serviceware, some baking and release papers, and grease-barrier coatings on paper cups and trays. The substances station set the testing ladder (total-fluorine screening, targeted confirmation); this guide applies it to the food lines, where substitution has performance consequences the testing must travel with.

Assume any legacy greaseproof specification is a question until screened. The sector's reformulation wave is already running on exactly that assumption.

Walk the range with the screening list: wrapped hot food (the wrap and its greaseproof grade), fried-food papers and cartons (the barrier is the product), bakery (bag and interleaving papers), moulded fibre (the wet-strength and grease system in the furnish), microwave and ovenable formats (susceptor and release treatments), and the paper cup's aqueous coating claims ('plastic-free' cups whose barriers deserve the same question). For each, the file needs the treatment's identity from the supplier - declared, screened where the declaration is thin, and substituted where the thresholds are crossed. Suppliers who reformulated early hold documentation as a selling point; suppliers who answer slowly are telling you the reformulation is not done.

The alternatives - physical grease barriers (dense papers, mechanical treatments), non-fluorinated coatings, clay and mineral barriers, and format changes (the fibre tray replaced by a board-and-window, the wrap by a bag) - each re-opens the food file: grease strike-through at serving temperature and dwell, shelf and display performance, migration of the new system, compostability or grade consequences, and the consumer's experience of a wrap that behaves differently. Substitution programmes should therefore run as reformulations with the full trial set, sequenced by exposure (highest grease load and longest contact first), and completed ahead of the date with stock run-out managed on the restrictions programme's discipline. A PFAS substitution discovered at the threshold date is a range outage wearing a compliance costume.

Substituted lines attract the 'PFAS-free' claim, which the claims framework handles strictly: the claim speaks to the packaging as placed (all components, adhesives and treatments in scope), to the evidence (screening at the method's limits, stated), and to the present tense (supply can drift; the claim rides on the substances station's supplier-declaration maintenance). Brands should also expect the retail and media question behind the claim - 'what was in it before, and when did you know' - and keep the programme's dates and screening records as the answer. In food, the substitution story told early and factually is a trust asset; told late, it is an admission.

Food is where PFAS substitution is furthest along, because food is where the question was asked first - by retailers, journalists and the Danish precedent that banned PFAS in paper food materials years before the Union's thresholds. The sector's remaining work is completion and proof: the long tail of small suppliers and imported serviceware, screened and documented to the same standard as the flagship lines. The threshold date will audit the tail, not the flagship. Spend the programme's last effort there.

The food PFAS programme's order of operations generalises across the substances station: screen the range, rank by exposure, substitute on trial data, document as you go. The businesses that inverted the order - positions first, screening when challenged - are reformulating under deadline with journalists copied in. Greaseproof paper is a humble material. It has ended more packaging careers this decade than any polymer, by being exactly where nobody looked.