Julie Simmons, Regulatory Affairs Manager and Bactiglas Specialist at Wells Performance Materials, explores the challenges of PFAS materials within recycling feedstocks following the recent changes in the European regulatory framework.
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Polymeric PFAS-based materials have been used extensively in the food packaging polyolefin film extrusion marketplace as highly efficient processing aids. They provide numerous benefits, including reducing melt fracture, die-lip buildup, lowering power requirements and enhancing output rates. As a result, they find their way almost ubiquitously into recycled feedstocks, which hasn’t been problematic until now.
However, Europe is rolling out ambitious plastic packaging rules that merge strict chemical safety standards with aggressive recycling targets. The EU’s Packaging and Packaging Waste Regulation (PPWR), effective February 2025 and applicable from August 2026, sets a lifecycle approach, covering design, recyclability, recycled content, reuse systems and chemical safety.
The PPWR’s most significant chemical restriction targets per- and polyfluoroalkyl substances (PFAS). From August 2026, food packaging can’t contain PFAS above the stated thresholds, in the ppb range for targeted PFAS molecules and 50 ppm for all PFAS, including polymeric PFAS (measured as total fluorine). This is essentially a ‘ban’ through concentration restrictions. It presents a substantial dichotomy to the industry when considering the drive for increased recycling content and a restriction on potential feedstocks. The industry estimates it could take at least five years for the PFAS materials to work their way through the system following the implementation of a global ban.
These recent changes bring several challenges to the polyolefin film extrusion industry. One is the search for alternative process aid masterbatches that offer similar performances to existing technologies, which are not based on PFAS technology. The other is to find and prove the compliance of recycled feedstocks that will meet the new PFAS restrictions of the legislation.
Wells PM has done extensive work on non-PFAS processing aid masterbatches for polyolefin film extrusion over the last few years. While PFAS materials tend to have a universal performance, possible substitute chemistries require more ‘fine-tuning’ for individual applications. As a result, the process aid masterbatch landscape will now change; rather than being dominated by one chemistry, it will likely have multiple solutions driven by customers’ process, polymer and performance demands instead of a one-size-fits-all. This more bespoke solution approach lends itself to developing more value-added, tailor-made products, which may incorporate other functionalities, such as heat stabilisation.
The PFAS restriction creates significant compliance challenges, as achieving the required sensitivity for detection at ppb levels demands sophisticated analytical chemistry capabilities. The exclusion of polymeric PFAS from certain calculations reflects the analytical difficulty of measuring these large molecules and the ongoing scientific debate about their environmental and health risks.
Under REACH, a broader PFAS restriction (covering ~10,000 substances) is under evaluation, with implementation expected in the early 2030s, and will cover many applications. It’s likely to include sector-specific derogations of several years for applications where immediate substitution is not feasible. However, this PPWR restriction has effectively fast-tracked regulatory action on PFAS in food packaging, taking effect years before the comprehensive REACH universal PFAS restriction is expected to be finalised.
Unlike the EU, the UK hasn’t implemented the PFAS restrictions in food packaging of the PPWR, creating complexity for companies operating in both markets. These face the choice of either maintaining separate PFAS-containing packaging for the UK market and compliant PFAS-free packaging for the EU, adding cost and complexity, or adopting the more stringent EU requirements across all products.
These regulations mark a shift toward integrated packaging governance where chemical safety and recyclability are inseparable. Meeting these requirements demands significant infrastructure investment, as companies must audit supply chains, possibly reformulate packaging, conduct testing and ensure compliance documentation systems.