PFAS-Free, Oil-Repellent Food Wrapping Paper: Three Real Boundaries—PFAS-Containing Oil Repellents / PFAS-Free Alternatives / 100ppm Total Organic Fluorine When a printing plant receives a “de-PFAS” redesign order, which three reports should it request from the customer first?

In January 2026, a bakery customer brought a roll of food wrapping paper to our counter and said, “The customer doesn’t want this paper anymore. See if you can print it.”

That roll of paper is greaseproof paper. Greaseproof paper is grease-resistant because its surface has a fluorinated greaseproofing agent (or is fluorinated using perfluorinated resin). PFAS-containing paper of this kind is being rapidly restricted in European and American markets.

The customer’s exact words were: “The United States says it can’t be used after 2025, and Europe says the same. First, tell me: can this actually still be used?”

This issue cannot be answered based on impressions, because PFAS-related regulations have varied in their pace, applicability, and limits over recent years. This article focuses on the three types of boundaries that printing companies truly need to monitor.

The first boundary: the report is not issued by the printing plant, nor by the same company

First, let us clarify one thing: The PFAS compliance test report is not issued by the printing plant. The printing plant is the user, not the party responsible for compliance.

The focus of PFAS regulations lies with food-contact material manufacturers—that is, the paper mill producing the greaseproof paper or the coating factory applying the coating. The printing plant should receive a certificate issued by the material supplier, rather than conduct testing itself.

The key is to distinguish three different things:

DocumentWho Issues ItWhat It CertifiesWhy the Printer Needs ItTotal Organic Fluorine (TOF) Test ReportPaper mill or third-party laboratoryTotal organic fluorine content in finished paperCalifornia AB1200 100ppm limitPFAS Substance List ScreeningThird-party laboratoryWhether specific restricted PFAS substances are presentSpecific substance prohibition list under California AB1200EU Declaration of Conformity / Supplier DeclarationEuropean supplier or importerComplies with REACH Annex XVII Entry 79Prerequisite for exporting orders to the EU

The core of California AB1200 comes down to two requirements: total organic fluorine in plant-fiber food packaging must not exceed 100ppm, and a list of specified PFAS substances must not be detected. These are not the same requirement: compliance with the total organic fluorine limit does not mean that the specified substance list has been passed, because some fluorinated substances have a low total fluorine content but are themselves on the prohibited list.

The European Union uses a different approach. REACH Annex XVII, Entry 79 sets restrictions on PFHxA (perfluorohexanoic acid), its salts, and related substances: the sum of PFHxA and its salts must not reach 25ppb, and the sum of related substances must not reach 1000ppb. These requirements apply to paper and paperboard intended for food contact from 10 October 2026. The 25ppb limit is extremely stringent—it measures the content in “homogeneous material”.

Therefore, when a printing plant receives this type of order, it should obtain the reports that the material supplier is required to provide, rather than ask whether the printing plant can issue such a report. Our plant’s practice is to include the following statement in the order confirmation:

“PFAS-related compliance and testing reports shall be provided by Party A’s packaging material supplier. Party B shall perform printing in accordance with the compliance materials provided by Party A.”

The second type of boundary: fluorine-free alternatives are not simply a matter of “switching paper”

The customer's second follow-up question was: "What if we switch to fluorine-free paper?"

Okay, but there is a cost, and it is not in the price; it is in the printing.

There are two approaches to the oil-resistant mechanism of oil-resistant paper:

Route 1: Fluorinated chemical oil-resistant agents (PFAS-based) are applied to the paper surface, leveraging the low surface energy of fluorine atoms to provide oil resistance. They offer excellent oil resistance, give the paper surface a slippery feel, and are low-cost.

Route 2: Fluorination treatment (grease-resistant paper / cellophane-type process) — The entire sheet is fluorinated, making its surface grease-resistant. It offers good performance, but the process is specialized.

There are three main paths for fluorine-free alternatives:

Alternative routesHow to do itOil resistanceChallenges for printing companiesWater- or Alcohol-Based Oil RepellentOil-repellent treatment using fluorine-free chemicalsModerate; sufficient for most applicationsReduced adhesion; the ink film is easily smudgedCoating SubstitutionUse fluorine-free water- and oil-resistant coatings (commonly water-based acrylic)Good, but adds a lamination layerAdds a coating process and narrows the heat-sealing windowAll-paper solutionNo oil-resistant treatment; instead, use a packaging structure with a linerAddress the issue through structural design rather than materialsIf the customer changes the box type, the structural design workload increases

Our factory’s actual experience was that after switching to fluorocarbon-free paper, ink adhesion was the first issue to emerge.

Fluorinated paper surfaces inherently have low surface energy and are naturally more difficult for ink to adhere to than ordinary paper. Previously, this issue was masked by using enough oil-resistant agent and applying a sufficiently thick ink layer. After the change, the customer reduced the ink layer thickness by 20% to cut costs, and as a result, the ink on the first batch of 3000 boxes rubbed off after just one wipe when they came off the production line.

Therefore, after receiving the fluorochemical-free paper, the printing plant must do at least two things:

1. Redo the adhesion test. The test should not be conducted on the original paper sample, but on the customer-specified final material, because laminated paper, coated paper, and print suitability are three entirely different matters.

2. Confirm whether the ink-setting method and drying conditions need to be adjusted. Water-based ink is more prone to drying without achieving proper anchorage on low-surface-energy paper stock. At our factory, the approach is to increase the drying temperature or extend the paper travel speed, but this must first be verified through sample testing and cannot be changed directly in production settings.

There is another easily overlooked point: the ink itself may also contain PFAS.Some specialty inks and finishes use fluorinated additives. Strictly speaking, when a customer requests a “PFAS-free package,” you need to consider the entire system—paper, coatings, inks, and adhesives—not just the paper.

The third type of boundary: switching suppliers affects print compatibility

The third category of boundaries only came to light at the very end, and they were also the most expensive.

The actual process for many customers is like this: the brand owner requests “PFAS-free” → the procurement department switches to a different paper mill → new paper samples are submitted → the printing plant runs the job using the old formulation.

The problem is that, to a printing plant, switching to a different paper mill almost means changing every parameter.

The paper mill has changed, and all of the following will change:

Paper Surface Treatment (Sizing Method)——From AK to AKS to ASA, each has different ink spreading and drying characteristics.

Coating Weight and Coating Structure—For the same 300g coated paper, a heavier coating reduces ink absorbency; reduced ink absorbency means slower drying, which makes overprinting prone to registration drift.

Antistatic performance and moisture content—The electrostatic performance varies among paper mills with different sizing systems, which in turn affects flying ink, registration accuracy, and stacking.

Stiffness and curl direction—especially for products involving a pasting or laminating process, such as gift boxes and paper boxes, changes in curl direction can cause problems with binding and forming.

Our factory’s standard practice is as follows: For any order involving a change of paper mill, new samples must be produced before the first production run, and mass production may begin only after the customer has signed off on the sample. This is not needless process obsession—it is a matter of cost. Our factory learned this lesson the hard way when it once proceeded directly to mass production without sample confirmation: 8,000 gift box bodies were affected. Because the stiffness direction of the new paper had changed, the four corners curled up after laminating. All were scrapped during rework, resulting in a material processing loss of more than 30,000.

We have always remembered the customer's exact words: "We replaced the paper ourselves. How is this your fault?"

Our answer then, as it is now, is this: The printer must be responsible for “what is printed using this batch of paper,” provided that the printer knows how this batch differs from the previous one. The customer’s failure to notify the printer when changing paper is an information gap; the printer’s failure to produce new samples after receiving the new paper is a process gap. Of these two issues, the second is the printer’s own responsibility.

Three lists for receiving a “PFAS-Free” order

Turn the three types of boundaries above into actionable measures:

What to requestWho to request it fromWhat it is used for1. Total Organic Fluorine + Specific Substance Screening ReportParty A or Paper MillConfirm that the material complies with the limit requirements of the intended market2. Declaration of Conformity (EU Orders)European supplier or importerConfirm compliance with REACH Annex XVII Entry 793. New material sample + customer-approved sampleParty A / paper millRevalidate adhesion, drying, overprinting, and stiffness

All three are required before production begins. If any one is missing, we can proceed, but we must provide a written statement in the email: “Material compliance shall be determined on the basis of reports provided by Party A and its suppliers. We assume no responsibility for whether substances contained in the materials comply with the regulations of the intended market.”

To be perfectly honest, the most counterintuitive aspect of PFAS is that the stricter the regulations become, the less printing plants can rely on experience. In the past, when printing greaseproof paper, a printer’s hands-on feel was more useful than a test report; that is no longer the case—because regulations limit the levels of substances in the material, and printing plants cannot control which chemicals upstream suppliers use. They can only ensure that nothing is printed incorrectly.

Further Reading

Several boundaries concerning food-contact and environmental labeling are best considered alongside this article:

6 Types of Mandatory Food Packaging Labels—what else must be printed on food-contact packaging.

Compliant use of packaging recycling marks (PCR/recyclable/compostable)—another category of requirements communicated through symbols.

The Real Impact of the 3 Types of the New European PPWR Regulations on Printing Plants in 2026—the broader context behind this European development.

Gaps in Implementing the 4 Categories of Paper-Plastic Composite Packaging Recycling Label Standards—Why composite structures are difficult to recycle.