PFAS Testing: What 'PFAS-Free' Actually Means in Foodservice Packaging

PFAS-free is one of the most commonly-claimed and least-verified labels in foodservice packaging. The 11+ states with PFAS bans have varying enforcement, but all rely on either supplier attestations or chemical testing. This guide explains what those tests actually measure, how to read a PFAS-free claim, and what procurement teams should verify.

For the state-by-state PFAS regulation map see PFAS Bans on Foodservice Packaging. For BPI’s role in PFAS compliance see BPI Certification Explained.

What PFAS are

PFAS (Per- and Polyfluoroalkyl Substances) are a family of 9,000+ synthetic chemicals containing carbon-fluorine bonds — the strongest single bonds in organic chemistry. The same property that makes them effective (resistance to grease, water, heat) also makes them persistent in the environment (“forever chemicals”).

In foodservice, PFAS were historically used as:

• Grease-resistance coatings on paper wrappers, bags, plates
• Hydrophobic coatings on fiber containers (bagasse, molded pulp)
• Stain resistance on cardboard food packaging
• Non-stick surfaces on cooking-related disposables

The two most-studied PFAS compounds are PFOA and PFOS — both linked to health concerns including kidney/testicular cancer, immune system effects, and developmental impacts.

The testing methods

Three approaches are used to verify PFAS-free claims:

1. Supplier attestation

The simplest method: the manufacturer signs a statement that no PFAS was intentionally added to the product. State regulations often accept attestation as sufficient evidence of compliance.

Strengths: Cheapest, available immediately Weaknesses: No verification; relies on supplier honesty Use case: First-tier compliance; backup for testing

2. Total Organic Fluorine (TOF) testing

Measures the total amount of fluorine in the organic fraction of the product. Since most PFAS contain fluorine, TOF is used as a proxy for total PFAS content.

Typical threshold: 100 ppm total fluorine = compliant (varies by regulation)

Strengths: Catches intentionally-added PFAS at typical use levels; relatively affordable ($150-300 per sample) Weaknesses: Can give false positives from non-PFAS fluorinated compounds; doesn’t identify specific PFAS chemicals

3. Targeted PFAS analysis

Uses high-resolution mass spectrometry (LC-MS/MS, GC-MS) to identify and quantify specific PFAS compounds (PFOA, PFOS, GenX, etc.) at parts-per-billion levels.

Strengths: Identifies specific chemicals; very low detection limits; gold-standard verification Weaknesses: Expensive ($500-2,000+ per sample); only detects PFAS compounds in the targeted method (may miss novel PFAS)

For most procurement decisions, TOF testing is the right balance of rigor and cost. Targeted PFAS analysis is for high-stakes compliance verification (litigation defense, premium brand claims) or for specific PFAS compounds of concern.

How to verify a PFAS-free claim

For procurement teams: Three layers of verification:

1. Get a supplier attestation in writing — signed statement of no intentionally-added PFAS, with the date and authorized signature
2. Request the TOF or PFAS test result — if the supplier has tested, they should be willing to share results
3. Independent verification (high-stakes) — for new suppliers or new product lines, an independent lab test gives confidence

For a typical procurement decision (sourcing a new line of bagasse plates from a new supplier in a PFAS-regulated state):

• Attestation = first step, always
• TOF result from a recent batch = second step, recommended
• Independent third-party test = optional, for highest-stakes claims

Reading test reports

A proper PFAS test report includes:

1. Sample identification — what was tested (product, manufacturer, lot)
2. Test method — TOF, EPA method 537.1, ASTM, etc.
3. Detection limit — what the test can detect (often expressed as ppb or ppm)
4. Results — measured values vs detection limits
5. Lab credentials — accredited (ISO 17025) labs are more reliable

A common red flag: reports that show “non-detect” without listing the detection limit. “Non-detect” at a high detection limit (e.g., 50 ppb) is not the same as “non-detect” at a very low limit (e.g., 1 ppb). Always verify the detection limit.

What about manufacturing-stream contamination?

Even products with no intentionally-added PFAS can have trace levels from:

• Recycled paper inputs — PFAS-contaminated paper recycled into new products
• Production water — water systems contaminated with environmental PFAS
• Shared manufacturing equipment — equipment previously used for PFAS-containing products

These contamination sources can produce trace PFAS detection even when no PFAS was added. Regulations typically allow for this — focusing on intentional addition rather than absolute zero.

The 100 ppm fluorine threshold in some state laws (Maine, New York) is calibrated to catch intentional PFAS use (which typically results in 1,000-10,000+ ppm fluorine) while allowing for trace contamination.

BPI certification and PFAS compliance

Since BPI’s 2020 standard update prohibits intentionally-added PFAS, a current BPI certification is effectively a PFAS-free certification for regulatory purposes. For products carrying the current BPI logo:

• No supplier attestation needed (BPI is the third-party verification)
• TOF testing not needed (covered by BPI standard)
• Compliance with state PFAS bans typically met

Caveat: Older inventory predating the 2020 update may carry BPI logos but contain PFAS. Verify the manufacturing date or current BPI listing for clarity. For inventory turning over after 2024, current BPI certification reliably indicates PFAS-free status.

State-by-state verification requirements

Different state PFAS laws require different verification:

The pattern: most states accept attestations; Maine is the strictest with actual testing required. For multi-state operations, meeting Maine’s standard satisfies all the others.

Common procurement mistakes

1. Accepting “PFAS-free” claims without supporting documentation — if there’s no attestation or test result, the claim is unverified
2. Buying old inventory and assuming it’s PFAS-compliant — pre-2020 BPI-certified products may contain PFAS
3. Confusing “PFAS-free” with “compostable” — they’re related but separate properties
4. Buying from suppliers that change formulations without disclosure — verify current production runs, not historical formulations
5. Not extending verification to all SKUs — a supplier may have PFAS-free for one SKU but not others

Decision cheat sheet