FDA PFAS Food-Packaging Update | Bakery Bag Buyer Checklist

U.S. food-packaging buyers should no longer rely on the 35 FDA food-contact notifications that previously covered certain PFAS-containing grease-proofing agents for paper and paperboard. The U.S. Food and Drug Administration determined that these notifications ceased to be effective on 6 January 2025 after the notified uses were abandoned. A limited compliance period for certain existing paper-packaging stock ended on 30 June 2025. For 2026 orders, buyers should verify the specific barrier chemistry and the authorization basis of the finished package instead of accepting a generic “food-grade” claim.

What the FDA actually announced

The 35 notifications had covered substances applied to paper and paperboard to resist oil and water. The FDA said the manufacturers or suppliers had stopped producing, supplying or using those substances for the notified food-contact applications. The agency had already reported in February 2024 that grease-proofing substances containing PFAS were no longer being sold by manufacturers for food-contact use in the U.S. market.

This is a specific regulatory development, not a claim that every paper package or every barrier coating contains PFAS. It also does not mean that every non-PFAS substitute is automatically suitable for all foods. The intended food type, contact time, temperature and construction still determine which supporting information a buyer should request.

Where the issue touches real products

Bakery bread bags

A printed food-paper bread bag may use a laminated layer to manage moisture or grease. The buyer should identify every food-contact layer, specify whether the food is dry, oily or warm, and request evidence for the proposed finished structure. The existence of a laminate does not by itself establish PFAS content or U.S. compliance.

Sandwich and takeaway boxes

A kraft sandwich box with a PET lid combines different materials. Paperboard, any surface treatment, printing and the plastic lid should be reviewed according to their actual contact with food. Oil-rich fillings, sauces and condensation make barrier selection and leak testing especially important.

A five-point RFQ checklist for U.S.-bound paper packaging

Describe the food and use conditions. State whether the package holds dry bakery goods, greasy sandwiches or hot takeaway food, plus maximum contact time and temperature.
Request the complete material structure. Record paper grade, coatings or laminates, adhesives, inks and the intended food-contact surface.
Ask for the regulatory basis. The supplier should identify the applicable authorization or other lawful basis for each relevant food-contact substance in the proposed structure.
Verify the PFAS statement precisely. Ask what substances and tests the claim covers; avoid treating a broad “PFAS-free” label as a substitute for a technical declaration.
Approve a finished sample. Test oil resistance, moisture handling, seams, lid fit and printing using the actual food or an agreed representative condition.

What suppliers and buyers should do next

For new U.S. programmes, procurement and quality teams should keep a version-controlled specification, supplier declarations, relevant test reports and sample approvals together. If the paper treatment, laminate, ink or converter changes, the compliance review should be repeated for the revised construction. Buyers serving both U.S. and other markets should identify destination requirements separately rather than assuming one document covers every market.

XHANCO can discuss paper and laminated packaging options against a buyer’s intended application. Send the food type, dimensions, barrier target, printing artwork, destination market and estimated volume through the enquiry page so that the proposed construction and documentation can be reviewed before mass production.

FDA PFAS Food-Packaging Update: A 2026 Checklist for Bakery Bags and Sandwich Boxes