Introduction
Why PFAS is back in the spotlight
If you are responsible for packaging, you’ll know that PFAS is no longer a background issue; it’s now a pretty significant topic of conversation amongst businesses. You may have seen it described as a “forever chemical” in the media; this alone tells you why brands are paying attention.
PFAS stands for per- and polyfluoroalkyl substances. They are a large group of man-made chemicals that are used for their resistance to water, grease, heat, and stains.
In packaging, this has made them particularly useful for food-contact materials, coatings, and barrier layers.
PFAS do not break down naturally, and some build up in the environment and in the human body, and certain types have actually been linked to serious health concerns. As scientific understanding grows, so does the scrutiny of PFAS use and the regulatory landscape governing them.
In this guide, we’ll explore what PFAS actually are, why they have been used in packaging, how they are regulated in the UK, and what brands should be doing now to manage risk and stay compliant.
Contents
What are PFAS?
Understanding the "forever chemicals"
PFAS are a family of synthetic chemicals developed and used since the mid-20th century. They are built around strong carbon-fluorine bonds, which make them extremely stable, and that stability is what gives them their performance benefits and makes them so difficult to remove from the environment.
There are thousands of different types of PFAS substances. Some estimates suggest that there may be millions of variations.
Not all PFAS behave the same way, though, and not all pose the same level of risk. However, several well-known examples, such as PFOA and PFOS, have been heavily restricted or banned due to health and environmental concerns.

These substances have been used in so many everyday products, from waterproof clothing and non-stick cookware to firefighting foams and electronics. In packaging, they are most commonly associated with grease-resistant papers and boards, particularly in fast food and takeaway applications.
Since PFAS substances don’t degrade, they can accumulate in soil, water, wildlife, and humans. Research has, in fact, linked certain PFAS substances to cancers, thyroid disease, high cholesterol, fertility issues, and pregnancy-related conditions, but evidence of this varies across substances.
Why have PFAS been used in packaging?
Performance benefits that are hard to replace
Packaging used for food often needs to be oil- and moisture-resistant while maintaining its strength and appearance. PFAS-based coatings have delivered that performance with relatively low material and weight cost.
In fast-moving consumer goods, product spoilage and leaks are frequent issues. PFAS coatings have reduced the risk of these issues arising and made PFAS substances more attractive, thanks to their reliability, especially since alternatives have historically been limited or more expensive.
They have also been valued for their thermal stability. PFAS offers a convenient solution for hot food applications due to its resistance to heat and grease.
However, what once looked like a wise choice now carries reputational and legal risks. The argument that PFAS substances are essential to packaging is becoming harder to defend as safer alternatives improve and regulatory pressures increase.
The regulatory landscape in the UK
How PFAS are controlled under UK law
In the UK, PFAS fall within the scope of UK REACH (the Registration, Evaluation, Authorisation, and Restriction of Chemicals regime).
This system requires manufacturers and importers to understand and manage the risks associated with the chemicals they place on the UK market.
Some PFAS substances are already restricted. For example, specific substances like PFOA and PFOS are already heavily restricted, and certain uses have already been phased out. Other PFAS substances appear on the UK REACH Candidate List of Substances of Very High Concern (SVHCs), which can trigger notification and supply chain communication obligations.

It’s important to note that Northern Ireland remains aligned with EU REACH, which is rapidly tightening restrictions on the use of PFAS substances. For brands operating across the UK, this creates a dual-compliance environment. A substance permitted in the UK might be treated differently in Northern Ireland under EU Packaging and Packaging Waste Regulations.
In recent years, the Health and Safety Executive (HSE) has been reviewing further restrictions, including proposals targeting PFAS in firefighting foams. While this doesn’t directly concern packaging, it signals a broader policy direction towards reducing non-essential PFAS use.
Persistent Organic Pollutants (POPs)
When PFAS are effectively banned
Certain PFAS substances are also regulated as Persistent Organic Pollutants under international agreements that are implemented in UK law. These substances are subject to restrictions on manufacture, sale, and use, with limited exemptions.
PFOS, PFOA, and PFHxS are among the PFAS that have been banned or subject to severe restrictions under the POPs regime. For packaging businesses, this matters because liability can arise not only from manufacturing but also from placing non-compliant products on the market.
The Persistent Organic Pollutants rules also extend to waste management. If waste contains certain PFAS substances above their specified concentration limits, it may be classified as POPs waste. In such cases, the substances must be destroyed or irreversibly transformed, and cannot be recycled in the normal way.
For UK businesses with sustainability commitments under the Packaging Waste Regulations and Extended Producer Responsibility (EPR), PFAS contamination that prevents the recycling of packaging materials will create compliance challenges.
A packaging format that appears to be recyclable in theory may be legally restricted in practice if it contains PFAS above the specified threshold levels.
Product safety and packaging risk
Could PFAS make a product 'unsafe'?
General product safety also plays an important role here. In the UK, businesses must ensure that only safe products are placed on the UK market. This obligation doesn’t apply solely to the manufacturer; other members of the supply chain may also carry responsibility.
If credible scientific research suggests that the presence of PFAS in a packaging material poses a risk to consumers under normal use, regulators could argue that the product fails the general safety requirement. This would be a serious issue as placing an unsafe product on the market is a criminal offence.

The real challenge here is uncertainty.
Not all PFAS substances are equally hazardous, and exposure levels vary widely depending on the application. Either way, as public awareness increases, regulators may adopt a more precautionary stance, especially for products used by children or those that come into direct contact with food.
You shouldn’t wait to clarify your business’s position through enforcement. Making proactive risk assessments, supported by robust testing and clear supplier information, is increasingly becoming part of good governance rather than an optional extra.
Environmental liability and site contamination
The long tail of PFAS risk
Where contamination is discovered, for example, at a manufacturing or storage site, companies may face remediation obligations under contaminated land regimes or environmental permit rules.
As PFAS substances don’t readily break down, cleanup can be complicated and expensive. In the UK and EU, estimates suggest that the long-term cost of managing PFAS pollution could run into the trillions over the coming decades.
For businesses, this risk can arise during property transactions, mergers, or site redevelopment. Historical use of PFAS-containing materials might not have been documented clearly, creating information gaps that complicate due diligence.
Even as regulatory standards evolve, civil negligence claims remain a possibility.
What should brands be doing now?
Practical steps for packaging manufacturers
First of all, you need to understand your exposure. This means mapping where PFAS might be present in our packaging portfolio, including coatings, barrier layers, inks, and treatments. Supplier declarations alone might not be enough, and targeted testing might be necessary for higher-risk applications
Secondly, you should review your regulatory footprint. If you operate in both the UK and Northern Ireland, or export to the EU market, ensure you track differences in REACH requirements and proposed restrictions.
Thirdly, explore the alternative options that are available to you. Many paper and board manufacturers now offer PFAS-free grease-resistant solutions.
Finally, consider your communication. Green claims that imply a product is “non-toxic” or “chemical-free” can create legal risk if they can’t be substantiated. Always back your claims with evidence.
Summary
Turning regulatory pressure into an advantage
PFAS substances are a complicated and evolving issue. They sit at the centre of chemistry, public health, environmental protection, and product safety. For packaging teams, they represent both a compliance challenge and a strategic turning point.
In 2026, ignoring PFAS is no longer an option, and while not all PFAS are banned or restricted, regulations are clearly moving towards tighter controls and phase-out of non-essential use.
Businesses that act early, through material audits, engaging their suppliers, investing in alternatives, and strengthening their internal governance, are likely to be better positioned.
Those who wait for formal bans and restrictions may find themselves reacting under pressure.
Ultimately, managing PFAS in packaging materials is about protecting consumers and the environment, and building long-term consumer trust with your brand.
If you’d like support reviewing PFAS risks within your packaging portfolio, get in touch with our team of packaging experts to discuss your compliance strategy.
About the author

David is responsible for driving improvements in sustainability at GWP and the wider Macfarlane Group, having previously performed a similar role for Zero Waste Scotland.
Important note
Due to the sensitive and regulated nature of the topic this guide addresses (eco-friendly packaging) we have taken extra steps to ensure its accuracy and reliability. You can find out more in our content policy.
All information is, to the best of our knowledge, accurate and correct at the time of publication. Please also note that, as all scenarios vary, not all information contained in this guide may apply to your specific application. There may also be specific regulations or laws, not covered within this particular guide, that apply. Please view the list of sustainable packaging regulations for further details.
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