A supplier telling you their packaging is “PFAS-free” is a marketing statement, not proof. With a growing list of states banning intentionally added PFAS in food packaging and the EU’s Packaging and Packaging Waste Regulation setting hard concentration limits starting August 2026, a verbal or emailed assurance won’t hold up if a regulator, retailer, or customer ever asks you to back it up.
This guide walks through the actual paper trail and lab testing you should require before you accept a PFAS-free claim from any packaging supplier — what documents to ask for, what the numbers on a lab report actually mean, and the mistakes that let bad claims slip through.
Quick Answer
Verify a PFAS-free packaging claim with two separate pieces of evidence, because US and EU/California rules test for different things and neither substitutes for the other. First, get a signed PFAS declaration naming the specific product and batch and stating that no PFAS was intentionally added — this is what most US state packaging bans actually turn on, since most of them have no concentration safe harbor at all, so even a trace of an intentionally added PFAS can violate the law no matter how low it measures. Second, where a numeric limit applies — under the EU’s Packaging and Packaging Waste Regulation or California’s law — get a Certificate of Analysis (CoA) from an accredited third-party lab showing total organic fluorine (TOF) or targeted PFAS results below that specific threshold. A lab report showing a clean ppm or ppb number does not, by itself, prove US compliance, and a signed declaration does not, by itself, prove you clear the EU’s or California’s numeric limits — you need the document that matches the law you’re actually trying to satisfy.
Step 1: Get the Right Documents, Not Just a Promise
Start with a written supplier declaration, but treat it as a starting point, not the proof itself. A usable declaration names the supplier’s legal entity, the exact product and spec number, a clear statement that no PFAS or PFOS was intentionally added during manufacturing, the regulation it’s being certified against, and a signature with date and batch or production range. Vague claims like “our packaging is eco-friendly and PFAS-free” on a website or sell sheet, with no product-specific backup, should be treated as a red flag.
Then ask for the Certificate of Analysis behind that declaration. A real CoA names an accredited lab (look for ISO/IEC 17025 accreditation covering PFAS or fluorine testing), states the test method used, gives a result in parts per million or parts per billion, and ties the sample to the specific packaging item and lot — not a “representative product line.” If a supplier can only offer a generic certificate that doesn’t name your product, ask them to test the actual SKU.
Keep every declaration and CoA on file. Several state laws (Connecticut’s among them) attach penalties for false certifications, and documentation requests can come from retailers, auditors, or regulators years after a purchase — a five-year retention habit is a reasonable default.
Step 2: Understand What the Lab Numbers Mean
Most PFAS-free testing starts with total organic fluorine (TOF), a screening test that combusts the packaging sample and measures fluoride released — since PFAS are the main reason packaging contains organic fluorine, a low TOF reading is strong indirect evidence the material is clean. If TOF comes back elevated, a lab should follow up with targeted PFAS analysis (LC-MS/MS) that identifies and quantifies specific PFAS compounds rather than just total fluorine.
Here’s the part that trips people up: US state packaging laws and the EU’s packaging regulation are not testing the same thing, and passing one does not mean you pass the other. Most US state bans (Vermont, Connecticut, Maryland, and others) prohibit PFAS that was intentionally added, full stop — there is generally no concentration safe harbor, so even a trace amount of an intentionally added PFAS can violate the law regardless of how low it measures on a lab report. California is the one state that also writes in a numeric backstop: packaging is “regulated” if PFAS was intentionally added or if total organic fluorine is at or above 100 ppm, whichever comes first. The EU’s Packaging and Packaging Waste Regulation, by contrast, works purely on concentration thresholds — no more than 25 ppb for any single targeted PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for total PFAS including polymeric PFAS — regardless of whether the PFAS was added on purpose or showed up incidentally.
The practical effect: a CoA showing the material tests below the EU’s ppb thresholds does not establish compliance with a US state’s intentional-addition ban — a supplier could intentionally use a tiny amount of a fluorinated grease-resistance coating that stays comfortably under the EU’s numeric limits yet still breaks a US state’s ban simply because it was added on purpose. You need the supplier’s sourcing and formulation declaration to cover the US intentional-addition question, and separate lab testing against the applicable numeric threshold for California or the EU. One test does not substitute for the other.
Check the units carefully either way — ppm and ppb are three orders of magnitude apart, and a report that looks reassuring at a glance can actually exceed the limit you need to meet if you misread the scale.
Step 3: Match the Claim to Where You’re Selling
A dozen states — including California, Colorado, Maine, Minnesota, New York, Oregon, Vermont, and Washington — now restrict intentionally added PFAS in food packaging or food-service ware, and more states add bills every legislative session. Scope varies: some laws cover only fiber-based packaging (paper bags, wraps, pizza boxes), others reach coatings, inks, closures, and shipping containers too. Confirm the supplier’s declaration covers the specific component you’re worried about, not just the base substrate, and get them to state plainly whether any coating, ink, or additive was selected for grease- or water-resistance using a fluorinated chemistry.
If you manufacture or import packaging materials into the US, also check whether EPA’s TSCA Section 8(a)(7) PFAS reporting rule applies to your supply chain — it requires reporting on PFAS manufactured or imported (including as part of an article) going back to 2011, separate from any state packaging ban.
When in doubt, ask the supplier directly which standard their declaration and test were made against. A CoA written only to the EU’s ppb/ppm thresholds does not establish compliance with intentional-addition rules under US state law, and a declaration that only addresses intentional addition doesn’t tell you the material clears the EU’s or California’s numeric limits — you need both documents, each aimed at the standard that actually governs the market you’re selling into.
Tips / Common Mistakes
Don’t accept a CoA for a different product than the one you’re buying — ‘this material family tested clean’ is not the same as your exact SKU testing clean, since coatings, inks, and additives vary by run.
Don’t assume a clean EU-style concentration test clears you under most US state laws. Those bans turn on whether PFAS was intentionally added, not on a ppm or ppb number, so a low lab reading doesn’t override a ‘yes’ on intentional addition — California is the main exception, since it also applies a 100 ppm total-organic-fluorine backstop.
Don’t rely on a single old test. Formulations and sourcing change; ask how often the supplier retests, and re-verify if they switch resin suppliers, coating vendors, or manufacturing sites.
Don’t skip the accreditation check. A lab report from a facility without ISO/IEC 17025 accreditation for PFAS methods carries far less weight in a dispute or audit.
Don’t confuse ‘recyclable’ or ‘compostable’ labeling with PFAS-free — compostability certifications like BPI’s do include a PFAS limit, but a product can be PFAS-free without being compostable, and vice versa, so check each claim separately.
Do put PFAS-free requirements directly into your purchase agreements or supplier contracts, with language requiring notice if a formulation changes — that gives you contractual recourse, not just a filed piece of paper, if a claim turns out to be wrong.
Explore more: More packaging compliance guides.
PFAS-Free Packaging Verification FAQs
Is a supplier’s signed PFAS-free statement enough on its own?
No. Treat a signed declaration as a starting point. You need an accredited lab’s Certificate of Analysis tied to the specific product and batch before you can rely on the claim, and for US sales you still need the declaration to explicitly address intentional addition, since most state laws don’t have a concentration safe harbor that a lab result could satisfy on its own.
Does passing the EU’s PFAS limits mean I’m also compliant with US state packaging laws?
No. Most US state bans prohibit PFAS that was intentionally added, with no concentration threshold that lets a low lab result override that, while the EU’s Packaging and Packaging Waste Regulation sets numeric concentration limits regardless of intent. The two are different legal tests, and you need to satisfy each separately — California is the exception, since it also uses a 100 ppm total-organic-fluorine threshold alongside its intentional-addition ban.
What test should I ask a lab to run?
Start with total organic fluorine (TOF) screening, which is faster and cheaper. If TOF comes back elevated, follow up with targeted PFAS analysis (LC-MS/MS) to identify and quantify specific compounds. Keep in mind this testing establishes a concentration number, not whether PFAS was intentionally added — most US state laws need the latter addressed separately.
Which states currently restrict PFAS in food packaging?
States including California, Colorado, Connecticut, Hawaii, Maine, Maryland, Minnesota, New York, Oregon, Rhode Island, Vermont, and Washington have laws restricting intentionally added PFAS in food packaging or food-service ware, with coverage varying by material and component.
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Photo: Daderot / CC0, via Wikimedia Commons.