PFAS & Fluoropolymer Coating Guidance
Navigate Changing PFAS Requirements Without Compromising Performance
PFAS regulations are changing — but the implications for industrial coatings require context
New European PFAS requirements have created understandable uncertainty across manufacturing, engineering and regulated supply chains. The key is to distinguish between rules affecting specific products — such as food-contact packaging — and the coatings used on industrial machinery, components and equipment.
What has actually changed?
The EU Packaging and Packaging Waste Regulation (PPWR) begins applying from 12 August 2026. It introduces limits for PFAS in food-contact packaging placed on the EU market.
This should not automatically be interpreted as a blanket ban on fluoropolymer coatings used on industrial machinery or components. Equipment coatings need to be considered according to their particular chemistry, intended use, contact conditions, documentation and the regulations applicable to that application.
Separately, the proposed wider restriction of PFAS under EU REACH continues to progress. This wider process is important for long-term material and coating decisions, but it is distinct from the PPWR requirements applying to food-contact packaging.
How is the coated component used?
The first stage of any coating review is to understand exactly where the coated component sits within the process, what it comes into contact with and which performance or compliance requirements apply.
Direct product contact
Surfaces intentionally designed to contact food, pharmaceuticals, chemicals, packaging or finished products require close assessment of coating suitability, operating conditions and supporting documentation.
Incidental contact or exposure
Components may not be designed as primary contact surfaces but could reasonably encounter process materials during operation, transfer, cleaning, maintenance or component wear.
Non-contact engineering
Many machine components, tooling surfaces and engineering parts have no direct product contact. Their coating requirements may instead be driven by release, friction, wear, corrosion, temperature, electrical performance or chemical resistance.
Food-contact packaging is not the same as industrial equipment
Food-contact packaging
PPWR introduces specific PFAS concentration limits for food-contact packaging placed on the EU market from 12 August 2026.
Machinery, components & equipment coatings
A coating applied to an industrial component is a different application. Suitability should be assessed using the coating chemistry, component function, exposure conditions, operating environment, end market and supporting technical documentation.
Fluoropolymer or alternative coating?
There is no single coating answer for every industrial application. The correct route depends on what the surface needs to achieve, the operating environment and the evidence available for the proposed system. Marcote's fluoropolymer coating services include systems selected around the performance requirements of the component.
When fluoropolymers may remain appropriate
PTFE, PFA, FEP and other fluoropolymer systems offer combinations of properties that can be difficult to reproduce with a single alternative.
High-release or low-friction performance is critical.
The process involves demanding temperatures or thermal cycling.
Chemical resistance is an important performance requirement.
The selected coating is appropriate for the intended application and can be supported by relevant documentation.
When an alternative should be explored
Where the process does not rely on the particular characteristics of a fluoropolymer, Marcote can assess whether another coating technology can achieve the required performance.
The customer has an internal PFAS reduction or material-substitution policy.
The required release performance can be achieved using another coating chemistry.
Future regulatory exposure forms part of the customer's procurement or risk assessment.
A documented alternative can meet the mechanical and operational requirements of the component.
Performance still matters
Replacing a proven coating purely on the basis of its chemical family can introduce new problems if the alternative cannot withstand the actual operating conditions. Marcote evaluates regulatory considerations alongside release performance, temperature, wear, chemical exposure, cleaning regimes and expected service life.
A structured route to the right coating decision
Rather than applying a blanket material policy, Marcote can review the application and establish which coating technologies are technically appropriate.
Application review
Identify the component, substrate, contact or exposure conditions, operating environment, cleaning regime and current coating system.
Performance requirements
Define the release, friction, temperature, corrosion, wear and chemical-resistance requirements that the coating must achieve.
Coating route assessment
Compare appropriate fluoropolymer and alternative technologies according to the actual demands of the process.
Technical documentation
Review the information available for the proposed coating system and ensure claims made about its composition or intended use are supported.
Recommendation & ongoing traceability
Provide a coating recommendation that considers both operational performance and the customer's documentation and risk requirements.
Documentation, traceability and customer risk assessment
Material selection is only part of the decision. Customers increasingly need to understand exactly what has been specified, why it was selected and what evidence supports the coating system used.
Coating identification
Clearly identify the coating system proposed for the component rather than relying on generic terminology.
Application conditions
Record the intended use, operating temperature, contact or exposure conditions and other relevant process requirements.
Supporting information
Retain the available technical and supplier information associated with the specified coating system.
Traceability
Maintain a clear link between the component, selected system and coating work carried out.
A note on “PFAS-free” claims
Marcote should only describe a coating as PFAS-free where that description is supported by the precise coating system and the documentation available for it. Where this cannot be established, a more specific description of the coating technology should be used.
PFAS and industrial coating FAQs
Are fluoropolymer coatings now banned in industrial applications?
No blanket industrial-coating ban arises simply from the PFAS limits introduced by PPWR. PPWR's specific limits relate to food-contact packaging. Industrial coating applications need to be assessed according to the coating system, intended use, end market and the regulations or customer requirements relevant to them.
Does PPWR mean PTFE-coated industrial machinery is banned?
No. PPWR specifically regulates packaging and includes PFAS limits for food-contact packaging. A PTFE-coated industrial component is not automatically the same legal category as food-contact packaging. Its intended use and applicable requirements should be assessed separately.
Can Marcote provide alternatives to fluoropolymer coatings?
Marcote can assess alternative coating technologies where they are technically suitable for the application. The recommended system will depend on factors including release requirements, temperature, wear, substrate, chemical exposure and cleaning conditions. Where a fluoropolymer remains appropriate, see Marcote's fluoropolymer coating service for more detail.
Should we replace all PTFE, PFA or FEP coatings now?
Not necessarily. Removing a coating without considering why it was originally specified can compromise release performance, durability or process reliability. Marcote recommends assessing each application individually and identifying whether a technically appropriate alternative exists.
Can Marcote confirm whether a coating is PFAS-free?
Any PFAS-free statement should relate to a specific coating system and be supported by appropriate documentation. Marcote will not rely on a generic PFAS-free claim where the available evidence does not support it.
What information should we provide for a coating review?
Useful information includes the component and substrate, current coating, intended use, contact or exposure conditions, operating temperature, process materials, cleaning chemicals, wear conditions, existing specification and the reason for reviewing the coating.
Unsure what PFAS changes mean for your coating application?
Send Marcote details of your component, existing coating and operating conditions. Our team can review the application, discuss the available coating routes and help you make a technically informed decision.
Discuss Your ApplicationEU Regulation 2025/40 — Packaging and Packaging Waste Regulation (PPWR).
European Commission guidance on the application of PPWR PFAS requirements to food-contact packaging, June 2026.
For the wider EU REACH position, see the European Chemicals Agency's PFAS restriction update .
Regulatory requirements continue to develop. Information on this page should be used alongside the requirements applicable to the customer's specific product, market and application.
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