A customer recently asked:
“Your test report shows a fluorine content of 23.9 ppm. Does this mean the product does not meet EU PFAS requirements?”
At first glance, the answer may seem simple. However, a result of 23.9 ppm fluorine does not automatically mean 23.9 ppm PFAS or indicate non-compliance.
To assess the result correctly, buyers should first identify what was tested, what was measured, and which EU requirements apply.
1. First, What Does “23.9 ppm Fluorine” Mean?
The most important point is that Total Fluorine (TF) is not the same as PFAS concentration.
A Total Fluorine test measures the total amount of fluorine in the tested sample. PFAS can contribute to this result, but other fluorine-containing substances may also be present.
Therefore:
- 23.9 ppm Total Fluorine = 23.9 mg/kg total fluorine
- It does not automatically mean 23.9 ppm PFAS
- A Total Fluorine result should not be described as a PFAS concentration unless PFAS itself was specifically analyzed
This distinction is particularly important when reviewing food-contact packaging under the EU Packaging and Packaging Waste Regulation (PPWR).
2. Next, Check the Units: ppm vs. ppb
EU PFAS requirements use both ppm and ppb, so unit conversion can easily confuse.
| Measurement | Equivalent |
|---|---|
| 1 ppm | 1 mg/kg |
| 1 ppb | 1 µg/kg |
| 1 ppm | 1,000 ppb |
| 23.9 ppm | 23.9 mg/kg |
| 23.9 ppm | 23,900 ppb |
| 25 ppb | 0.025 ppm |
| 250 ppb | 0.25 ppm |
| 50 ppm | 50 mg/kg |
However, unit conversion does not change what was measured.
For example, 23.9 ppm Total Fluorine can be expressed as 23,900 ppb Total Fluorine, but it is still Total Fluorine—not 23,900 ppb PFAS.
3. What Does the EU PPWR Require?
The next step is to determine whether the packaging falls within the relevant PPWR PFAS requirements.
Under Regulation (EU) 2025/40, from 12 August 2026, food-contact packaging must not be placed on the EU market when PFAS concentrations reach or exceed the specified limits, subject to the conditions in the Regulation. Article 5(5) specifies:
- 25 ppb for any PFAS measured by targeted PFAS analysis
- 250 ppb for the sum of PFAS measured by targeted analysis, where applicable
- 50 ppm for PFAS including polymeric PFAS
Importantly, these are not three interchangeable testing methods. The applicable limit depends on what is being measured and which analytical method is used.
Moreover, if Total Fluorine exceeds 50 mg/kg, the Regulation provides for evidence showing how much fluorine is attributable to PFAS or non-PFAS for the technical documentation.
4. Does 23.9 ppm Total Fluorine Mean the Packaging Fails?
For food-contact packaging, the answer is not necessarily.
The European Commission’s current guidance recommends a stepwise approach because there is currently no harmonised EU-level testing method specifically for PFAS in food-contact packaging.
At Step 1, Total Fluorine is measured. If TF is below 50 mg/kg, the sample may be considered compliant. The Commission also states that, based on the evidence currently available, samples compliant with Step 1 are also compliant with the subsequent steps.
In this example:
23.9 ppm = 23.9 mg/kg
and:
23.9 mg/kg < 50 mg/kg
Therefore, if the report is genuinely measuring Total Fluorine in the relevant food-contact packaging, a result of 23.9 ppm falls below the 50 mg/kg threshold used in Step 1 of the Commission’s current guidance.
However, this should not be rewritten as “23.9 ppm PFAS is compliant.” The test result is still a Total Fluorine result.
5. What If the Report Actually Says “23.9 ppm PFAS”?
That is a different situation.
If a laboratory report specifically states 23.9 ppm PFAS, then:
23.9 ppm = 23,900 ppb PFAS
This result must be assessed against the applicable PFAS limit and the analytical method used.
For food-contact packaging, the PPWR contains the 25 ppb, 250 ppb, and 50 ppm limits described above.
Therefore, buyers should never compare a Total Fluorine result directly with a PFAS concentration limit without first confirming what the laboratory actually measured.
6. Which Packaging Is Covered?
Another important question is the scope of the requirement.
The specific PFAS limits in Article 5(5) apply to food-contact packaging. The European Commission describes this as packaging intended to come into contact with food, or already in contact with food and intended for that purpose.
Examples include:
- Food bags and wrappers
- Food containers
- Food-contact paper and cardboard
- Other packaging intended to directly contact food
Meanwhile, non-food packaging is not automatically subject to the Article 5(5) PFAS limits simply because it is packaging.
Nevertheless, other requirements may still apply depending on the material, intended use and applicable EU or national legislation.
For example, PPWR Article 5(4) sets a combined limit of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium in packaging and packaging components.
Therefore, the correct approach is to identify the packaging’s intended use first and then determine which requirements apply.
7. Why Does the Test Method Matter?
The test method is just as important as the number shown on the report.
For example, a laboratory may report:
- Total Fluorine (TF)
- Individual PFAS
- Sum of targeted PFAS
- Other fluorine-related measurements
These results cannot simply be treated as equivalent.
In addition, the Commission’s current guidance recommends further analytical steps when Total Fluorine exceeds 50 mg/kg. For example, techniques such as pyrolysis-GC/MS may be used to help determine whether the fluorine is organic or inorganic. Direct TOP analysis may also be used to assess the relevant PFAS thresholds.
As a result, a buyer should always check the test item, test method and reported parameter before drawing a compliance conclusion.
8. Packaging Compliance Is Not the Same as Product Compliance
Another common mistake is using a packaging test report to prove that the product itself is compliant.
For example, a food-contact product may be supplied in:
- A printed paper box
- A plastic bag
- A paper insert
- Labels or other packaging components
The packaging and the product may be subject to different regulatory requirements.
Therefore, a fluorine test performed on packaging should not automatically be used as evidence that the product itself complies with food-contact requirements.
9. What Other Requirements Should Buyers Check?
PFAS is only one part of packaging compliance.
Depending on the packaging and its intended use, buyers may also need to review:
- Heavy metals
- Food-contact requirements
- Migration testing
- Material composition
- Packaging minimisation
- Recyclability
- Recycled-content requirements
- Packaging labelling
- Supplier declarations
- Technical documentation
- Traceability
In particular, PPWR requires compliance with the relevant chemical requirements in Article 5(4) and 5(5) to be demonstrated through technical documentation prepared according to Annex VII.
Therefore, one laboratory report should not be treated as a complete packaging compliance file.
10. What Should Buyers Ask When They See “23.9 ppm Fluorine”?
Before accepting or rejecting a test report, ask the supplier these questions:
- Does 23.9 ppm refer to Total Fluorine or PFAS?
- What exact material or packaging component was tested?
- Is the packaging intended for food contact?
- Which test method was used?
- Does the report clearly identify the tested parameter and unit?
- Can the supplier provide the relevant technical documentation and supporting test reports?
These questions can prevent one of the most common misunderstandings: treating a Total Fluorine result as if it were a PFAS concentration.
11. Key Takeaways
A test result of 23.9 ppm Total Fluorine does not automatically mean that a product or package contains 23.9 ppm PFAS or fails EU PFAS requirements.
For food-contact packaging, the EU PPWR sets specific PFAS limits, while the European Commission’s current guidance recommends a stepwise approach starting with Total Fluorine. Under that guidance, TF below 50 mg/kg may be considered compliant at Step 1.
Therefore, when reviewing a fluorine test report, follow this order:
1. Identify what was tested → 2. Identify what was measured → 3. Check the unit → 4. Confirm whether the packaging is food-contact → 5. Apply the relevant PPWR requirement → 6. Review the supporting documentation.
More importantly, 23.9 ppm Total Fluorine should not be automatically converted into a PFAS concentration. The measurement itself must remain clearly identified throughout the compliance assessment.
Free EU PPWR Packaging Compliance Checklist
For suppliers, importers, purchasing teams and brand owners, a practical checklist can make the review process easier.
The downloadable checklist covers packaging identification, food-contact status, PFAS/Total Fluorine review, chemical requirements, supporting documentation and key compliance points.
Download the EU PPWR Packaging Compliance Checklist to use it when reviewing supplier documents and laboratory reports.
Official EU References
Regulation (EU) 2025/40 — Packaging and Packaging Waste Regulation
EUR-Lex — Regulation (EU) 2025/40
European Commission Guidance — PFAS in Food-Contact Packaging
