- Aug 6
- 10 min read
From packaging and release applications to conveyor belts, seals, lubricants and other processing equipment, PFAS can be closer to the bakery process than many manufacturers realise. With new EU requirements taking effect and wider restrictions under development, now is the time to understand where these substances may occur, what the legislation requires and how bakeries can prepare.
Per- and polyfluoroalkyl substances, better known as PFAS, have become one of the most closely watched groups of chemicals in Europe.
PFAS are not a single substance but a large family of synthetic chemicals. Different regulatory systems use different definitions and scopes, which can make the subject particularly difficult for companies trying to establish exactly which substances and products should be included in a PFAS inventory.
PFAS are valued because many have exceptional resistance to heat, chemicals, water and grease, together with useful low-friction and non-stick properties. These characteristics have led to their use in numerous industrial and consumer applications, including food-contact materials and food processing equipment.
The same persistence that makes many PFAS useful also creates environmental concerns. The European Chemicals Agency (ECHA) describes PFAS as a large group of synthetic chemicals and highlights their persistence and widespread environmental presence.
For bakeries, the issue is therefore not simply whether PFAS are present in food packaging. They can also occur in equipment and materials used during production.
A useful way to look at the subject is through three questions:
What are PFAS and where might a bakery encounter them?
What legislation is already in force, and what is coming?
What should bakeries do now?
What are PFAS and where might a bakery encounter them?
The practical reason PFAS have been so widely used is their combination of properties. Depending on the substance, PFAS can provide resistance to heat, oil, grease, water and chemicals, together with low friction and non-stick characteristics.
The ECHA is the EU agency responsible for implementing key aspects of EU chemicals legislation. Based in Helsinki, it provides scientific and technical expertise on chemicals, manages information on chemical substances and supports EU regulatory decision-making. Its scientific committees assess issues including proposals for restrictions, with their opinions feeding into the EU decision-making process.
Packaging and release products
The most familiar bakery applications are likely to be those that deliberately exploit PFAS' grease-resistant or non-stick properties.
These include certain food-contact papers and boards, non-stick coatings and release-related applications. The European Commission identifies oil-resistant coatings for paper and cardboard food-contact materials among PFAS applications.
However, packaging and release agents are only part of the picture.
Processing equipment
The regulatory picture is particularly relevant to bakery equipment because fluoropolymers are used in a range of industrial components.
ECHA's PFAS use-mapping work identifies fluoropolymers and perfluoropolyethers in applications including seals, gaskets, piping, linings, valve parts and packing. Its machinery category includes self-lubricating and low-friction elements, bearings, belts, rollers and protective or durable coatings.
For a bakery investigating PFAS, potential points of investigation therefore include:
Conveyor belts and belts used in processing equipment;
Rollers and low-friction machine components;
Seals, O-rings and gaskets;
Pipe and hose linings;
Valve and pump components;
Fluoropolymer liners and coatings;
Certain bearings and bushings;
Lubricants containing fluorinated materials;
Other fluoropolymer components used for heat, chemical or friction resistance.
The presence of a PFAS-containing component does not, by itself, establish that PFAS are migrating into food. That distinction is important.
For example, the US Food and Drug Administration identifies certain PFAS-containing sealing gaskets and O-rings used in food processing equipment as authorised food-contact applications in the United States. Its assessment of the particular polymerised and crosslinked materials covered by that authorisation concluded that migration was expected to be negligible.
The question for a bakery is therefore twofold: Does a component contain PFAS and does its particular use create a relevant exposure or regulatory issue?
The indirect sources
Another complication is that PFAS may not always be obvious from the formulation of the finished product or from the major pieces of equipment.
A 2026 analysis published by regulatory intelligence company Enhesa identifies potential indirect sources of PFAS in manufacturing operations, including industrial cleaners, degreasers, lubricants, oils and processing aids. It also highlights PFAS precursors, which can transform or degrade into other PFAS.
This means a useful PFAS review should look beyond deliberately added substances and consider where PFAS may occur throughout the manufacturing process and supply chain.
What legislation is already in force and what is coming?
Europe's PFAS regulatory landscape is developing on several fronts. Some individual PFAS and applications are already restricted, while new requirements are now coming into force for food-contact packaging and a much broader restriction under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) is progressing through the EU regulatory system.
PFAS already subject to EU restrictions
Several individual PFAS and groups are already regulated under EU chemicals legislation and the EU Persistent Organic Pollutants Regulation.
The EU POPs Regulation, Regulation (EU) 2019/1021, contains restrictions on substances including PFOS, PFOA and PFHxS, together with related substances and specified exemptions.
The EU has also adopted a specific REACH restriction covering PFHxA, its salts and PFHxA-related substances. The restriction applies to specified uses, including certain food-contact packaging applications, as well as some textiles, consumer products and other applications.
There are also legally binding maximum levels for certain PFAS in food. Regulation (EU) 2023/915 sets maximum levels for PFOS, PFOA, PFNA and PFHxS, individually and as a sum, in specified categories of food.
For food manufacturers, it is important to distinguish between limits on PFAS as contaminants in food and restrictions on PFAS-containing materials and products. They address different parts of the supply chain.
Food-contact materials
EU food-contact legislation is also relevant.
Regulation (EC) No 1935/2004 establishes the general framework for materials and articles intended to come into contact with food. Materials must not transfer substances to food in quantities that could endanger human health, bring about an unacceptable change in the composition of the food or cause deterioration in its organoleptic properties.
The framework covers materials and articles used in food production and processing, while specific materials may also be subject to additional EU or national requirements. Good manufacturing practice is addressed by Regulation (EC) No 2023/2006.
For bakeries, this means PFAS can be relevant not only as a chemicals management issue, but also in the context of food-contact materials and processing equipment where the relevant legal requirements apply.
A significant date for bakery packaging
For bakery businesses selling into the EU, one PFAS date deserves particular attention: 12 August 2026.
This is the general application date of the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, commonly known as the PPWR. The Regulation entered into force on 11 February 2025, although different provisions come into application at different times.
Among the PPWR's requirements is a specific restriction on PFAS in food-contact packaging.
From 12 August 2026, food-contact packaging must not be placed on the EU market if it contains PFAS at or above any of three specified thresholds:
25 ppb for any PFAS, measured using targeted PFAS analysis, with polymeric PFAS excluded from quantification;
250 ppb for the sum of PFAS measured by targeted analysis, where applicable following prior degradation of precursors, again with polymeric PFAS excluded from quantification;
50 ppm for PFAS including polymeric PFAS.
Where total fluorine exceeds 50 mg/kg, the regulation also establishes an information requirement concerning the quantity of fluorine attributable to PFAS or to non-PFAS substances, so that the relevant technical documentation can be prepared.
The European Commission has published guidance on the application of the PFAS provisions. It notes that there is currently no harmonised EU analytical method specifically for PFAS in food-contact packaging, and describes a stepwise approach using available analytical methods.
For bakeries, the requirement applies to food-contact packaging placed on the EU market. This makes the issue immediate for businesses selling packaged bread, cakes, biscuits, pastries and other bakery products into the EU.
It is also a supply chain issue as much as a testing issue. A bakery may buy its finished packaging from one supplier, but PFAS could have entered the material through a coating, barrier or other treatment further upstream.
A supplier declaration is therefore useful, but it should be supported by appropriate technical information and where necessary, analytical evidence.
Why testing is not necessarily straightforward
'PFAS testing' is not necessarily one simple laboratory test.
The PPWR sets its limits using different analytical measures, including targeted PFAS analysis and total PFAS including polymeric PFAS. The European Commission's guidance therefore describes a stepwise approach rather than relying on a single universal analytical method.
This matters because a negative result from one analytical approach does not necessarily answer every question about fluorinated substances in a packaging material.
For higher-risk materials, particularly those designed to provide grease or moisture resistance, bakeries should discuss the appropriate testing strategy with their packaging supplier and laboratory.
Keep an eye on changing formulations
Compliance should not necessarily be treated as a one-off exercise.
Packaging suppliers can change raw materials, coatings or barrier technologies. A material that has been assessed at one point in time may therefore need to be reassessed if its formulation changes.
Bakeries should establish how suppliers will communicate relevant changes and when declarations or supporting evidence need to be renewed.
This is particularly important where packaging is purchased through several tiers of the supply chain. A bakery may have a direct relationship with a packaging converter without having direct visibility of the coating or chemical supplier further upstream.
The bigger development: The proposed EU-wide PFAS restriction
The biggest change on the horizon is the proposed EU-wide restriction of PFAS under REACH.
Authorities from Denmark, Germany, the Netherlands, Norway and Sweden submitted the original restriction proposal in 2023. Following an extensive consultation, the proposal was updated in August 2025. ECHA's scientific committees have since been assessing the proposal and its possible socio-economic consequences.
In March 2026, ECHA's Risk Assessment Committee (SEAC) adopted its opinion on the scientific aspects of the proposed restriction, while the Committee for Socio-Economic Analysis continued its assessment.
Following a further consultation, SEAC is expected to adopt its final opinion by the end of 2026. The process then moves towards the European Commission and Member States as part of the REACH decision-making process. The eventual restriction will determine the precise legal requirements, including any derogations, transition periods and application-specific provisions.
For industry, this means that the final outcome is still to come, but companies have an opportunity to identify PFAS uses and investigate alternatives before any future requirements take effect.
What can bakeries do now?
The sensible response is not to wait for every detail of future legislation to be settled.
The proposed REACH restriction is still moving through the legislative process and its final scope, exemptions and transition periods will determine exactly what manufacturers will have to do. But there is already enough information available for bakeries to begin preparing.
Start with an inventory
The first step is to establish where PFAS may be deliberately or unintentionally present. For a bakery, that means looking beyond ingredients and packaging and asking equipment suppliers about:
Food-contact and process components
Conveyor belts;
Baking and processing surfaces;
Coated trays and moulds;
Rollers;
Scrapers and guides;
Liners;
Seals and gaskets;
Hoses, pipes and valves.
Maintenance products
Lubricants and greases;
Cleaning and degreasing products;
Processing aids;
Specialist coatings.
Site operations
Firefighting foams;
Wastewater streams;
Waste containing PFAS;
Historical uses and potential contamination.
ECHA's use-mapping work is based on this kind of application-level visibility: understanding PFAS according to uses, applications and exposure pathways, rather than simply searching for the names of a handful of familiar PFAS.
Ask suppliers better questions
One of the easiest traps is to ask a supplier: Is this PFOA-free?
That is not the same as asking whether the material contains PFAS within the definition relevant to the particular EU requirement being considered. A product can be free of one well-known PFAS while containing another substance within a broader PFAS definition.
For companies buying complex equipment or packaging, it is therefore more useful to request a formal PFAS declaration from the supplier, identifying the relevant material or substance and the basis for the declaration.
For food-contact packaging, suppliers should also be able to provide the information needed to demonstrate compliance with the PPWR requirements applicable from 12 August 2026 and supplier management should not end with the first declaration. Companies should have a process for dealing with material or formulation changes, including changes to coatings, barriers or other treatments.
Prioritise rather than panic
Not every PFAS-containing component presents the same potential exposure.
A fluoropolymer incorporated into a seal is not necessarily equivalent to a PFAS-containing substance deliberately applied to a food-contact surface.
The sensible approach is to rank applications according to:
Whether PFAS are intentionally present;
Whether the material contacts food;
Temperature and duration of contact;
Whether the component is subject to abrasion or wear;
Whether PFAS can migrate or be released;
Whether the material enters wastewater or waste streams;
Whether an alternative is already available;
The expected service life of the equipment.
This is particularly important for bakeries because replacing an inexpensive processing aid is one thing; replacing a tunnel-oven belt, coating or major piece of production equipment is quite another.
Start substitution conversations early
The final EU-wide restriction is expected to contain derogations and transition arrangements rather than simply switching every PFAS application off overnight. ECHA's committees have recognised the need for targeted derogations in their assessment of the proposed restriction.
That does not mean manufacturers should wait. If a bakery has identified a PFAS-containing belt, coating, seal or lubricant, now is the time to ask the equipment or materials supplier:
Is a fluorine-free alternative available?
Has it been validated for the same temperature and food-contact conditions?
Does changing the material affect cleaning or sanitation?
Does it alter belt life or machine performance?
Is the alternative already being supplied in the EU?
What is the expected lead time for replacement?
Can existing equipment be converted, or does it require a new machine?
An alternative material also needs to work. Packaging and equipment changes can affect grease resistance, moisture protection, shelf life, cleaning, machine performance and durability. Substitution should therefore be treated as a technical qualification exercise, not simply a procurement exercise.
Keep records
Good documentation will become increasingly important as PFAS requirements develop.
For a bakery, useful records include:
Supplier declarations;
Technical specifications;
Safety and product information;
Equipment bills of materials where available;
PFAS statements;
Records of substitutions;
Test reports;
Waste and wastewater information;
Dates of equipment replacement;
Records of relevant formulation or material changes.
The objective is not to create paperwork for its own sake. It is to be able to demonstrate what was assessed, what the supplier said, what was tested and when the assessment was made. That information can also make future substitutions and regulatory changes much easier to manage.
What does this mean for the bakery sector?
PFAS should not be approached simply as another chemical on a list.
The regulatory challenge is broader because PFAS is a large chemical family, definitions differ, individual substances are already regulated, specific applications are being restricted, new packaging requirements are taking effect and a much wider restriction is moving through the REACH process.
For packaging, there is already a concrete deadline: food-contact packaging placed on the EU market from 12 August 2026 must meet the PPWR's PFAS requirements. For the wider range of PFAS uses, the regulatory picture is still developing. ECHA's scientific committees are continuing their work on the proposed REACH restriction, with SEAC's final opinion expected by the end of 2026.
For bakery manufacturers, the practical message is straightforward:
Find the PFAS first.
Once a bakery knows where PFAS are being used, it can distinguish between applications that are already regulated, applications likely to be affected by future restrictions and applications where safer or fluorine-free alternatives can be adopted now.
That turns PFAS from a future compliance surprise into an engineering, procurement and risk management exercise that can be planned, rather than imposed.
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