Two dates decide most of this story, and both have already arrived or are months away.
In the United States, the FDA announced in February 2024 that grease-proofing substances containing PFAS were no longer being sold into the U.S. market for paper food packaging. In the European Union, a restriction on PFAS in food-contact packaging entered into application on 12 August 2026 under the Packaging and Packaging Waste Regulation. And on 1 January 2027, New Hampshire’s prohibition on food packaging and containers takes effect — the next date on the U.S. compliance calendar.
If you buy takeout containers, bowls, cups or wrappers, this is no longer a sustainability talking point. It is a specification question.
What PFAS are, and why food packaging was the target
PFAS is the shorthand for per- and polyfluoroalkyl substances. The definition used across U.S. state laws is consistent and narrow: fluorinated organic chemicals containing at least one fully fluorinated carbon atom.
The reason food packaging drew attention is functional, not decorative. As the FDA explains, grease-proofing agents are substances applied to paper and paperboard packaging to prevent leaking of grease, oil, or water. Because of their molecular structure and the way they are applied to the surface, that use can result in dietary exposure through transfer or migration into the food.
In other words, the coating that keeps a greasy burger from soaking through the box is the same coating that can migrate into it.
The U.S. federal picture is already settled
The FDA’s February 2024 announcement was not the result of a new federal ban. It followed voluntary market phase-out commitments from manufacturers, combined with earlier FDA regulatory actions.
The sequence matters for buyers:
- Between 2011 and 2016, grease-proofing agents containing long-chain PFAS — the “C8” compounds, including PFOA and PFOS — stopped being used for food contact in the U.S. market, and in 2016 the FDA revoked the regulations authorizing the remaining uses.
- In 2020, after the FDA reviewed new data on a short-chain PFAS known as 6:2 fluorotelomer alcohol (6:2 FTOH), manufacturers committed to phasing out those substances. The FDA has said it anticipated it might take until June 2025 to exhaust existing stocks.
- In January 2025, the FDA published a notice in the Federal Register that 35 food contact notifications related to PFAS-containing food contact substances in paper and paperboard packaging are no longer effective, because manufacturers or suppliers had abandoned them.
One detail worth internalizing: the FDA has also developed a screening method to detect grease-proofing agents containing PFAS in paper and paperboard packaging, so it can monitor the market for substances that are no longer authorized.
The EU limit is now live
The Packaging and Packaging Waste Regulation entered into force in February 2025 and its rules apply on a phased basis from 12 August 2026.
The European Commission describes the PFAS measure plainly: food-contact packaging containing PFAS above strict limits can no longer be placed on the EU market. The Commission notes that PFAS have commonly been used in food packaging such as takeaway containers, fast-food wrappers, microwave popcorn bags, bakery paper and pizza boxes, to repel water or grease.
Further PPWR obligations arrive later — a harmonised labelling system from 2028, and measures on empty space, certain single-use plastic packaging and recyclability from 2030 — but the PFAS restriction is the one already in force. The Commission published implementation guidance in March 2026.
For a supplier shipping into Europe, this changes the documentation you need, not just the material you buy.
Where U.S. states are going next
Federal action has not stopped state legislatures. As of a December 2025 compilation by the law firm BCLP, 14 states had enacted laws related to PFAS in food containers and packaging materials, with an additional 10 proposed bills pending.
State approaches divide into two families. Some use an “alternatives” framework, where a state agency assesses whether a commercially available option exists in sufficient quantity and at comparable cost. Others simply prohibit intentionally added PFAS.
Dates already in effect, from the same compilation, include California (1 January 2023, which pairs the intentionally-added test with a threshold of more than 100 ppm of PFAS measured as total organic fluorine), Connecticut, Maryland and Minnesota (1 January 2024), Colorado (1 January 2024), and Hawaii (31 December 2024, covering wraps and liners, plates, food boats and pizza boxes).
New Hampshire is next, on 1 January 2027.
Note the scope difference, because it decides whether a given item is covered: some states limit their definition to packaging comprised in substantial part of paper, paperboard or other plant-fiber materials, while others cover all food packaging.
Why fiber is not automatically PFAS-free
This is the trap that catches operators mid-transition.
Replacing foam with fiber solves the foam problem. It does not, by itself, solve PFAS. Grease and water resistance in fiber packaging has historically come from PFAS chemistry — which is exactly why the FDA’s phase-out targeted grease-proofing agents on paper and paperboard rather than a single product category.
So a fiber clamshell can be compliant on one axis and non-compliant on another. The material family is not the answer; the item’s chemistry is.
What to ask for before you commit
Three questions separate documented PFAS-free packaging from a marketing claim:
- Is PFAS intentionally added? Ask for it in writing, per SKU — not per category.
- What is the measured total organic fluorine? Where a jurisdiction sets a numeric threshold rather than an intent test, this is the number that matters.
- Which market is this item cleared for? A specification acceptable in one jurisdiction may not satisfy another.
Our packaging materials guide explains how fiber substrates differ in the first place, which helps you frame the right question to any supplier.
Where Max Green Pack fits
We manufacture PFAS-free packaging — paper and bagasse foodservice formats — in Thailand, and ship to North America and Europe. Our range covers the formats these rules touch most directly — bagasse bowls, bagasse plates, clamshells, cups, trays and takeout boxes.
Tell us your market and your menu, and we will map the items that need a specification review.
