PFAS measurements in recycled packaging could encourage virgin materials use
Under official UK framework, packaging will receive an automatic red rating if it contains more than 1ppm of total PFAS.
The Foodservice Packaging Authority (FPA) and the Packaging Federation have raised concerns over the treatment of per- and polyfluroualkyl substances (PFAS) under the Recyclability Assessment Methodology 2027 (RAM).
The proposed concentration thresholds could result in otherwise recyclable packaging receiving automatic red ratings and producers facing higher packaging Extended Producer Responsibility (pEPR) fees.
A central concern is whether the proposed thresholds are appropriate for determining packaging recyclability, rather than compliance with chemical restrictions.
The Packaging Federation argues that RAM must distinguish between the ability to recycle packaging, the safety and quality of recovered materials and the commercial value of the resulting recyclate. It warns that penalising unintentional contamination could discourage the use of recycled materials in favour of virgin alternatives.
PackUK – the administrator for pEPR - is considering alternative approaches to PFAS testing and verification, including different screening arrangements for food-contact and non-food packaging.
The FPA released a statement saying, ‘We are particularly concerned packaging could receive a red rating because compliance cannot be demonstrated, rather than because the material itself is difficult to recycle.
‘There are also important questions about how unintentionally present PFAS should be treated and whether the requirements could inadvertently discourage the use of recycled materials.
‘We are asking PackUK to retain the intentionally added distinction while the evidence is properly assessed, provide clear justification for any proposed concentration thresholds and align the approach as closely as possible with European requirements.
‘The objective must be to protect the environment without introducing unnecessary complexity or undermining the recycling outcomes pEPR is intended to deliver’.
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