Pyro-GC-MS (Pyrolysis coupled with Gas Chromatography–Mass Spectrometry)

PPWR and PFAS: A Positive Total Fluorine Result Is Not a Verdict

From 12 August 2026, Regulation (EU) 2025/40 (PPWR) introduces strict PFAS limits for food-contact packaging: 25 ppb for an individual PFAS, 250 ppb for the sum of PFAS, and 50 ppm as Total Fluorine.

However, a positive Total Fluorine result (TF > 50 ppm) does not automatically mean non-compliance.

The Total Fluorine test measures all fluorine present in the sample, including fluorine originating from inorganic sources or fluorinated organic compounds that do not meet the definition of PFAS. As a result, an apparent exceedance of the limit could be due to a false positive, potentially leading to the unnecessary rejection of an otherwise compliant product.

The solution, as outlined in the European Commission’s March 2026 guidance, is Pyro-GC-MS. This technique can distinguish Total Fluorine originating from PFAS from fluorine originating from “false positives” (inorganic fluorine-containing materials and fluorinated organic compounds that are not PFAS).

At TIL, we cover the entire analytical workflow, from Total Fluorine screening (C-IC, ISO/IEC 17025 accredited method) to the assessment of “false positives” using Pyro-GC-MS, and targeted PFAS analysis by LC-MS/MS.

🎥 Watch the video and read the full article to learn how to distinguish a real compliance issue from a false positive.

 

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FULL ARTICLE

PPWR and PFAS: A Positive Total Fluorine Result Does Not Automatically Mean Non-Compliance

How Pyro-GC-MS Distinguishes Real PFAS from False Positives and Prevents Unnecessary Non-Compliance of Food Packaging

Last updated: 16 July 2026 – by Test & Innovation Lab (TIL)

In Brief: From 12 August 2026, Regulation (EU) 2025/40 (PPWR) introduces strict limits on the presence of PFAS in food-contact packaging.The first screening test is Total Fluorine (TF). However, a positive result does not automatically mean that PFAS are present, because the measurement may also include inorganic fluorine and fluorinated organic compounds that are not PFAS. Pyro-GC-MS can determine whether the detected Total Fluorine is actually due to PFAS molecules or whether it originates from inorganic fluorine-containing substances and/or fluorinated organic compounds that are not PFAS, i.e. so-called “false positives.”

Watch the video to see how the analysis works and why it can make the difference between a compliant product and one incorrectly rejected.

 

What Does the PPWR Require for PFAS in Food Packaging?

Regulation (EU) 2025/40, known as the Packaging and Packaging Waste Regulation (PPWR), entered into force on 11 February 2025 and will apply directly and uniformly across all 27 EU Member States from 12 August 2026, replacing Directive 94/62/EC.

For food-contact packaging, Article 5 establishes three concentration thresholds that must not be reached or exceeded:

Parameter	Limit	Method
Individual PFAS (non-polymeric)	≤ 25 ppb (0,025 mg/kg)	Targeted analysis
Sum of PFAS (non-polymeric)	≤ 250 ppb (0,25 mg/kg)	Targeted analysis
All PFAS, including polymeric PFAS	≤ 50 ppm (50 mg/kg)	Measured as Total Fluorine unless it is demonstrated that the fluorine originates from non-PFAS sources

 

Three Often Overlooked Aspects:

• The limits apply regardless of whether PFAS are intentionally added or unintentionally present.
• They apply to the entire packaging unit, including inks, coatings, adhesives and varnishes.

No transitional period or sell-through period is provided. Packaging produced before 12 August 2026 but placed on the market afterwards must already comply. No exemption is available for recycled materials.

 

Why Does a Positive Total Fluorine Result Not Mean PFAS Are Present?

Total Fluorine (TF) is the first screening level and measures all fluorine contained in the sample.

The issue is that not all fluorine originates from PFAS. Elevated TF values may derive from:

• Inorganic fluorine (fluorides, mineral fillers, pigments);
• Fluorinated organic compounds that are not PFAS and may be present in additives or processing materials.

As a result, a TF value above the 50 ppm threshold is a warning signal, not proof of non-compliance.

Rejecting a product solely on this basis creates the risk that a false positive is responsible for the exceedance, potentially preventing the correct commercialization of the product. This is particularly relevant for grease-resistant paper and board applications, one of the historical uses of PFAS in food packaging.

Furthermore, there is currently no harmonized EU test method. The European Commission (March 2026 FAQs) is working with the EU Reference Laboratory for Food Contact Materials to develop a common protocol.

It should also be noted that the Commission’s guidance document and FAQs, although highly persuasive, are not legally binding. This makes it even more important to rely on a laboratory capable of managing the entire analytical process correctly.

 

What Is Pyro-GC-MS and How Does It Distinguish Real PFAS from False Positives?

Pyro-GC-MS (Pyrolysis Gas Chromatography-Mass Spectrometry) is a technique that differentiates fluorine originating from PFAS molecules from fluorine deriving from inorganic fluorine-containing materials (e.g., mineral fillers) and fluorinated organic compounds that are not classified as PFAS (e.g., chemical auxiliaries, colorants, etc.).

The sample is pyrolyzed and the resulting fragments are separated and identified by GC-MS.

Mass spectrometry provides the most suitable means of monitoring the presence of CF₃ and CF₂ fragments, which represent the structural units defining PFAS. According to the regulatory definition, a PFAS contains at least one fully fluorinated methyl or methylene carbon atom. This analytical approach allows the following:

• If CF₃ and CF₂ groups are detected, the presence of PFAS molecules in the sample is confirmed.
• If CF₃ and CF₂ groups are not detected, it can be presumed that the Total Fluorine result is attributable to a false positive, although further investigation and confirmation through targeted PFAS analysis remain necessary.

In conclusion, Pyro-GC-MS can be considered the bridge between initial screening (Total Fluorine) and targeted confirmation (LC-MS/MS or GC-MS) used to verify compliance with the 25 ppb and 250 ppb limits.

 

What Testing Approach Is Proposed by the European Commission Guidance?

The European Commission guidance published on 30 March 2026 describes a stepwise approach:

1. Step 1 — Total Fluorine (TF). If TF is < 50 ppm, the material may be considered compliant and no further testing is required.
2. Step 2 — Differentiation by Pyro-GC-MS. If TF is > 50 ppm, organic and inorganic fluorine are differentiated using a technique such as Pyro-GC-MS. If Total Organic Fluorine (TOF) is < 50 ppm, the material may be considered compliant.
3. Step 3 — TOP Analysis. To verify compliance with the limits for individual PFAS (25 ppb) and total PFAS (250 ppb), a TOP Assay (Total Oxidizable Precursors) is performed. This method oxidizes polyfluorinated precursors into perfluoroalkyl acids that can be quantified by LC-MS/MS.

 

TIL’s Technical Position: The Analytical Approach We Recommend

Based on the complexity of materials used in finished packaging and the variety of fluorine sources, the approach described in the guidance may present limitations in conformity assessment.

Two aspects deserve particular attention.

First, the screening resolution. Total Fluorine methods typically have quantification limits in the mg/kg range, whereas PFAS limits are expressed in μg/kg, a difference of approximately 1,000-fold.

A TF value close to the detection limit, if caused by PFAS, could still correspond to concentrations far above the 25 ppb and 250 ppb thresholds. Therefore, Step 1 alone does not provide sufficient metrological assurance with respect to these limits.

Second, the nature of the data generated in Step 3. The Regulation defines the 25 ppb and 250 ppb limits as requiring targeted analysis, whereas the guidance recommends the TOP assay. These two outputs are not equivalent because TOP measures the potential presence of oxidizable precursors rather than identifying individual PFAS molecules.

TIL’s Recommended Approach:

• Step 1 – Total Fluorine (TF): Initial screening and preliminary conformity assessment.
• Step 2 – Targeted PFAS Analysis: Essential to verify compliance with the individual PFAS limit (25 ppb) and PFAS sum limit (250 ppb), regardless of the Total Fluorine result.
• Step 3 – Pyro-GC-MS Differentiation: Applied only to samples with TF > 50 ppm and negative targeted PFAS results (all PFAS not detected), to determine whether the exceedance is due to polymeric PFAS or a false positive.

The Commission will review the PFAS restriction under the PPWR by 12 August 2030, providing yet another reason to establish a robust analytical dossier today.

 

What Should Companies Do Before 12 August 2026?

• Map food-contact packaging materials that may present PFAS risk, especially grease- and water-resistant packaging.
• Test the entire packaging unit according to a stepwise approach, including inks, coatings and adhesives.
• Document From 12 August 2026, manufacturers are responsible for conformity assessment (Article 38 and Annex VII) and for issuing the Declaration of Conformity. Supplier declarations alone are not sufficient.
• Act in advance. With no transitional period, compliant packaging must be ready before the application date.

 

How TIL Supports Companies in Achieving PPWR Compliance

Test & Innovation Lab (TIL) has Pyro-GC-MS, Combustion Ion Chromatography (C-IC) for Total Fluorine determination and LC-MS/MS for targeted PFAS analysis, allowing the laboratory to cover all analytical stages described in the guidance.

Our services include:

• Total Fluorine screening by Combustion Ion Chromatography (C-IC), an ISO/IEC 17025 accredited method.
• Evaluation of potential false positives using Pyro-GC-MS.
• Targeted PFAS analysis (LC-MS/MS) and PFAS sum determination through the TOP assay.

 

TIL offers a comprehensive analytical platform capable of assessing actual PPWR compliance and providing the technical evidence required to support the marketing and commercialization of your products.

▶ Contact TIL to verify the PPWR compliance of your food-contact packaging.

 

Frequently Asked Questions (FAQ)

 When does the PPWR PFAS restriction apply?

From 12 August 2026 for food-contact packaging placed on the EU market. No transition period or sell-through period is provided.

 What are the PPWR PFAS thresholds?

• 25 ppb for an individual PFAS (targeted analysis)
• 250 ppb for the sum of PFAS (targeted analysis)
• 50 ppm for all PFAS, including polymeric PFAS, measured as Total Fluorine

 Does a Total Fluorine result above 50 ppm mean the product is non-compliant?

No. Total Fluorine measures all fluorine present, including inorganic fluorine and fluorinated compounds that are not PFAS. Additional analytical investigation, such as Pyro-GC-MS, is required.

 What is the purpose of Pyro-GC-MS in PFAS analysis?

It determines whether detected fluorine originates from PFAS molecules or from non-PFAS sources by identifying the characteristic CF₃ and CF₂ fragments of PFAS structures. It therefore helps distinguish a genuine exceedance of the 50 ppm Total Fluorine limit from a false positive.

 Is Total Fluorine below 50 ppm sufficient to demonstrate compliance?

According to the Commission guidance, yes. Based on our experience, however, there are numerous cases where Total Fluorine complies with the 50 mg/kg limit while targeted PFAS analysis reveals non-compliance with substance-specific limits. We therefore recommend targeted PFAS analysis in all cases.

Do the limits apply only to intentionally added PFAS?

No. They apply regardless of intentional addition and cover the entire packaging unit, including inks, coatings and adhesives.

Is there a harmonized EU test method for PFAS in packaging?

Not yet. The European Commission is currently developing a common protocol. In the meantime, the stepwise approach described in the March 2026 guidance is followed.

Sources 

• Regulation (EU) 2025/40 (PPWR) – EUR-Lex.
• European Commission, PPWR Guidance Document and FAQs (30 March 2026).
• European Commission Environment Directorate, Packaging Waste webpage.