Don’t overlook other compliance requirements. The new USP chapter on plastic components became mandatory on May 1, 2026, and the FDA’s list of approved recycled plastics for food-contact use is also being updated. Food packaging involves a wide range of materials and complex regulations; compliance in a single area isn’t enough—you need to review your entire product line holistically.
For companies exporting food packaging, the biggest pitfall to avoid in 2026 is PFAS: state-level bans are taking effect across the U.S., a federal bill is set to launch on New Year’s Day next year, and the EU tightened its rules back in August. That makes for three different timelines for the same class of substances. This article outlines the latest developments in food packaging regulations so you can self-check your export orders for compliance.
State laws are leading the way. Currently, 12 states restrict the use of intentionally added PFAS in food packaging and food service ware: California, Colorado, Connecticut, Hawaii, Maine, Maryland, Minnesota, New York, Oregon, Rhode Island, Vermont, and Washington. Since effective dates and covered product categories vary by state, you must verify requirements against your specific target states rather than relying solely on federal standards.
Food packaging compliance is fundamentally about material management. PFAS bans are just the beginning; by establishing a comprehensive material inventory and certification dossier, you can remain confident regardless of how regulations change.
What does this mean for businesses? Before exporting food packaging to the U.S., you must verify whether grease-resistant coatings contain PFAS. Suppliers must be able to provide test reports and declarations of compliance. You should also pre-validate the performance of fluorine-free grease-resistant alternatives (such as water-based, wax-based, or bio-based coatings). Paper food containers, paper cups, and grease-resistant paper bags are key areas for inspection.
Let’s look at the U.S. federal level first. The FDA concluded its voluntary phase-out program for PFAS-based grease-resistant agents in early 2024 and rejected a petition for a total ban in June 2026. However, Congress is advancing the “PFAS in Food Containers Safety Act of 2026,” which proposes banning food packaging containing intentionally added PFAS from interstate commerce starting January 1, 2027. Once enacted, this federal legislation will apply nationwide.
How should you respond? Compile a bill of materials and map each item against regulatory requirements; maintain test reports and certification records so they are readily available for customer inquiries; include compliance clauses in supplier contracts to clearly define liability boundaries; and validate new materials through prototyping before moving to mass production—do not treat actual orders as experiments.
EU regulations are also tightening. The PPWR will become fully applicable on August 12, 2026, with simultaneous enforcement of PFAS restrictions for food-contact packaging; for food packaging exported to the EU, “PFAS-free” is no longer merely a selling point, but a prerequisite for market entry.
