Date: November 30, 2025 | Subject: EU Market Access Risk
On August 12, 2026, Article 5 of the EU Packaging and Packaging Waste Regulation (PPWR) enters full force. It does not just ban “intentionally added” PFAS; it enforces a hard cap on Total Organic Fluorine (TOF) at 50 ppm.
This creates an immediate market access failure for manufacturers relying on outdated risk assessment models.
Forensic analysis confirms that legacy processing aids push North American exports 140% over the legal limit.
Preliminary Forensic Analysis: Standard PLA/PHA formulations using fluorinated mold release agents routinely test between 60–120 ppm.
Any material testing >50 ppm is legally classified as a contaminant.
Our analysts specialize in polymer physics and biocomposite engineering in affiliation with the University of Guelph. Our research focuses on the intersection of circular economics and material compliance.
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This advisory is for informational and strategic planning purposes only. It does not constitute legal advice. Compoziq Intelligence assumes no liability for actions taken based on this data. Manufacturers should consult with their own legal counsel and certified testing laboratories for final compliance verification.