In separate responses submitted to PackUK’s PFAS technical subgroup, the two organisations have raised concerns about the scientific basis for the proposed measures and the practicality of proving compliance.
At PackUK’s request, the Packaging Federation also supplied additional evidence. It recommends retaining the existing ‘intentionally added PFAS’ distinction within the RAM framework unless new concentration limits are supported by robust technical and economic analysis.
Under the proposed RAM 2027 methodology, packaging would automatically receive a red rating where total PFAS exceeds 1 part per million (ppm). Food packaging would also receive a red rating if it contains more than 25 parts per billion (ppb) of any individual PFAS or of total PFAS.
The principal issue is whether these limits are suitable indicators of packaging recyclability, as opposed to thresholds designed to demonstrate compliance with chemical legislation. This distinction is particularly important as businesses respond to wider food and drink regulations and evolving food manufacturing trends.
The Packaging Federation says RAM should separately assess three factors: whether packaging can be recycled, whether recovered material is safe and sufficiently high quality, and whether the resulting recyclate has meaningful commercial value.
Although the federation recognises that PFAS contamination could affect recycling processes and the availability of viable end markets, it is questioning whether the proposed thresholds provide enough evidence to justify an automatic red classification. In its view, PackUK must demonstrate the effect of those limits on collection, sorting, reprocessing and the safe use of recovered materials.
The federation has also questioned whether an automatic red modulation would provide an additional environmental benefit where PFAS contamination lowers the value of recyclate. Expected income from recovered materials already forms part of the net waste-management costs calculated under pEPR. The key question, therefore, is whether the proposed classification would result in measurable improvements in recycling performance.
Both organisations have drawn attention to the possibility that PFAS may enter packaging unintentionally. Potential sources include recycled feedstock, environmental background contamination and manufacturing operations—issues that are increasingly relevant to food processing technology and supply-chain assurance.
The Packaging Federation refers to published studies showing that PFAS can occur in recycled paper and plastics. However, those studies do not establish how often packaging placed on the UK market would exceed the proposed limits. The federation warns that penalising incidental contamination could encourage manufacturers to choose virgin materials instead of recycled inputs, potentially undermining food and drink sustainability objectives.
The FPA’s Sustainability and Government Affairs (SAGA) Committee has separately called for compliance arrangements that reflect commercial realities. Where suitable, it recommends accepting supplier declarations and packaging specifications instead of requiring extensive laboratory analysis across large product portfolios.
The committee is also seeking closer consistency with the EU Packaging and Packaging Waste Regulation (PPWR), including alignment on test methods, the substances within scope and the treatment of trace contamination. Consistent requirements would help businesses manage cross-border supply chains while responding to wider food and drink packaging developments.
Nevertheless, the Packaging Federation emphasises that the PPWR’s chemical controls and RAM’s recyclability assessment have different purposes. Meeting European chemical requirements should not automatically determine whether packaging receives a red recyclability rating.
Following input from its technical subgroup, PackUK is examining alternative methods for PFAS testing and verification. These may include separate screening approaches for food-contact and non-food packaging.
This further consultation is a positive step because it gives industry an opportunity to explain how the proposed rules would operate in real manufacturing, distribution and recycling environments. It also reflects the need for policy to keep pace with food and beverage industry trends, food distribution trends and broader food and drink industry innovation.
However, significant issues remain unresolved. These include whether the proposed concentration limits are valid measures of recyclability and whether applying them could unintentionally affect investment in recycling infrastructure, packaging material choices or the use of recycled content.
The Packaging Federation maintains that any change to the automatic red classification should be based on transparent, material-specific evidence. That evidence must show a clear connection between the proposed thresholds and actual recycling outcomes, rather than simply demonstrating the presence of a chemical substance.
Technical discussions between industry representatives and PackUK are continuing.
Members with relevant PFAS test results, recycling trial findings or other technical information are encouraged to submit evidence. Further information is available in the new Have Your Say section below, providing an opportunity for businesses to contribute practical insight from across the food and drink supply chain, including food and drink marketing and packaging operations.
The FPA said: “We support the need for appropriate controls on PFAS, but RAM must remain a credible measure of packaging recyclability, supported by clear scientific evidence and practical compliance requirements.
“Producers need certainty about what evidence will be accepted to demonstrate compliance. Requiring extensive laboratory testing across potentially thousands of products, without practical alternative assurance routes, risks imposing an unreasonable burden on manufacturers and distributors. 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.”
It added: “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.”
