As international PFAS requirements for food-contact packaging tighten, Australia needs to consider what common, measurable standard should apply to packaging placed on our own market.
Australia is reconsidering how packaging is designed, used, recovered and ultimately managed at end of life.
That is an important and necessary transition.
But as circular-economy principles increasingly influence packaging design, recycling, organics recovery and product stewardship, another question deserves equal attention:
What chemistry are we putting into those circular systems in the first place?
PFAS in food-contact packaging provides an important example.
For several years, PFAS Free Australia has advocated for a clear and measurable Australian benchmark for PFAS and related chemicals of concern in food-contact packaging, including a maximum threshold of 40 ppm.
The purpose of establishing a common benchmark is not simply to attach another environmental claim to packaging.
It is to provide manufacturers, importers, converters, food businesses and purchasers with a common point against which products entering the Australian market can be assessed.
And that question is becoming increasingly important.
International expectations are changing
From 12 August 2026, the European Union’s Packaging and Packaging Waste Regulation introduced enforceable PFAS concentration limits for food-contact packaging.
Those requirements include limits for individual PFAS and groups of targeted PFAS, together with a 50 mg/kg threshold encompassing polymeric PFAS.
Importantly, the European requirements are concerned with what is present in the packaging — not simply whether a supplier states that PFAS was intentionally added.
That distinction matters.
A finished food package can incorporate paper, board, polymers, barrier chemistry, printing inks, adhesives, varnishes and other components. Recycled materials may also carry chemistry inherited from previous applications.
Understanding one raw material or receiving a declaration from one supplier does not necessarily establish the chemical status of the finished package.
This is already becoming an Australian market-access issue
The European requirements are not simply an overseas regulatory development.
In August, the Australian Government’s Department of Agriculture, Fisheries and Forestry issued Market Access Advice to Australian seafood exporters specifically drawing attention to the new European packaging requirements.
Exporters were advised of the PFAS limits and the need for technical documentation demonstrating packaging compliance with European requirements.
That creates an important question closer to home.
If Australian businesses increasingly need to understand and demonstrate the PFAS status of food packaging supplied into regulated export markets, what common standard should apply to packaging supplied to the Australian market?
Australia should not inadvertently become a lower-assurance destination for packaging simply because other markets require clearer evidence of chemical composition.
Nor should this be characterised as an argument against imported packaging.
Quite the opposite.
A credible national baseline should apply equally to packaging manufactured in Australia and packaging manufactured overseas.
Same Australian market. Same baseline. Same expectation.
Australia is already considering the issue
Australia is undertaking broader reform of packaging regulation, including consideration of mandatory design requirements and restrictions on chemicals of concern in packaging.
At the same time, the Australian Packaging Covenant Organisation has continued work arising from its voluntary program to phase out PFAS in fibre-based food-contact packaging.
APCO’s 2026 PFAS Discussion Paper considers expanding the phase-out beyond fibre-based food-contact packaging, reviews PFAS testing methodologies in light of regulatory developments and considers possible changes to thresholds and guidance.
These are important developments.
But Australia’s current industry-led approach remains voluntary.
Testing activity does not, by itself, create a common standard if products are not consistently tested, results are not consistently reported and different analytical approaches can answer quite different questions.
Not all PFAS testing asks the same question
PFAS is not a single chemical.
Different analytical methods can provide different information.
Targeted methods may identify a defined group of individual PFAS while leaving other fluorinated substances outside the analytical window. Broader screening approaches can provide a different indication of fluorine or organofluorine content but may not identify the individual compounds responsible.
How a sample is prepared can also matter.
So can the part of a multilayer package selected for analysis, the detection limits applied and whether testing is undertaken on a component, a surface or the finished package.
Consequently, two statements that packaging has been “PFAS tested” do not necessarily mean that equivalent questions were asked — or that equivalent evidence was obtained.
Where testing remains voluntary and multiple analytical approaches are available, cost, availability and familiarity can inevitably influence which method is selected.
This leads to a simple but important principle:
A test result can only answer the question the test was designed to ask.
A common Australian baseline therefore needs more than a number.
It also requires sufficient consistency around what is being measured, how it is measured and what evidence supports the resulting claim.
What should Australia’s baseline be?
For PFAS Free Australia, this question is not new.
For several years, we have advocated for a measurable maximum benchmark of 40 ppm for PFAS and related chemicals of concern in food-contact packaging.
The purpose is not to suggest that a single number resolves every analytical or regulatory question.
It is to establish something fundamentally important: a common point against which packaging supplied to the Australian market can be assessed.
International regulation is increasingly moving toward measurable product requirements.
Australia now has an opportunity to establish its own nationally consistent position rather than allowing different customers, suppliers, industry schemes and jurisdictions to develop different interpretations of what constitutes acceptable packaging.
A common baseline also provides manufacturers and suppliers with greater certainty about the standard they are expected to meet.
Circularity introduces another dimension
This is not only a food-contact issue.
It is also a circular-economy issue.
Packaging does not cease to contain chemistry when it enters a recycling bin, an organics system or another recovery pathway.
The chemistry travels with the material.
That becomes particularly important with persistent substances.
Recycled materials can carry legacy chemistry into subsequent applications. Food-soiled packaging can enter waste and organics systems. Coatings, inks, adhesives and other functional chemistries can affect what happens during collection and reprocessing.
International policy is increasingly recognising this connection.
In the United Kingdom, the Recyclability Assessment Methodology used under Extended Producer Responsibility already considers chemical contaminants, including PFAS, when determining packaging recyclability. The updated RAM 2027 further embeds chemical and system-level considerations into recyclability assessments, with those ratings influencing the disposal fees paid by obligated producers.
The principle is significant.
Chemical composition, packaging design, recyclability and producer responsibility are no longer entirely separate conversations.
Which brings us back to a simple proposition:
Circular packaging is only circular if we know what chemistry we are circulating.
A common baseline creates commercial certainty too
Clear standards do more than manage environmental and product risk.
They create a more level commercial playing field.
A manufacturer or converter that invests in alternative barrier technologies, supplier qualification, testing, traceability and product controls incurs real cost.
If that product competes against packaging supported only by a broadly worded supplier declaration, the Australian purchaser may have little ability to distinguish between two very different levels of evidence.
A nationally consistent and measurable baseline changes that equation.
It establishes a minimum expectation for everyone supplying the Australian market.
It also gives procurement teams something increasingly valuable: a common specification that can be communicated through the supply chain.
For businesses operating internationally, greater alignment with major regulated markets may also reduce the need to maintain different Australian and export packaging specifications.
The next question
Australia does not need to replicate another jurisdiction’s regulatory system word for word.
But we should be asking whether an advanced food and packaging market should continue without a clear, nationally consistent and measurable baseline for PFAS and relevant chemicals of concern in food-contact packaging.
PFAS Free Australia believes that baseline is needed.
We have advocated for it for several years.
The international direction of travel makes the question increasingly difficult to defer.
But establishing the number may ultimately prove to be only the first challenge.
Once Australia agrees what the standard should be, the next question is perhaps even more important: what evidence should demonstrate that a finished package actually meets it?
Because a number without a consistent means of establishing it is not yet a standard.
