EU PFAS Limits for Food Packaging: What Can-Coating Formulators Should Recheck
Updated: 2026
EU PFAS Limits for Food Packaging: What Can-Coating Formulators Should Recheck
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1. What Changed Under the EU PFAS Packaging Rules?
EU PPWR Article 5(5) applies PFAS concentration limits to packaging intended to come into contact with food from 12 August 2026. Food-contact packaging at or above the stated thresholds cannot be placed on the EU market. The limits are 25 ppb for any targeted PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for PFAS including polymeric PFAS.
For can-coating formulators, this is a whole-system reformulation issue. Changing a PFAS-containing ingredient can alter wetting, leveling, release behavior or compatibility depending on its original function. The governing source is the EU Packaging and Packaging Waste Regulation.
2. What Does This Mean for Can-Coating Formulators?
The useful question is not “What replaces PFAS?” Blocked polyisocyanates are not direct substitutes for fluorinated chemistry. The practical question is which variables must be re-balanced after a regulated ingredient changes: binder, additives, crosslinker, catalyst, solvent package, substrate, film build, oven profile and downstream forming or printing.
Dongsen supplies polyisocyanate hardeners and crosslinkers as raw materials, not finished can coatings. Final PFAS compliance, migration behavior and food-contact suitability remain finished-system responsibilities.

3. Where Does Crosslinker Selection Matter?
Blocked polyisocyanates keep NCO functionality capped during storage. Baking activates the blocked system so NCO can react with hydroxyl-functional resin and build a crosslinked network. That makes the crosslinker relevant to cure response, adhesion and chemical resistance in a 1K coating.
Crosslinker selection is one part of the reformulation problem, not the PFAS solution itself. It cannot be used as evidence of PFAS replacement or food-contact compliance.
Related technical reading: blocked isocyanate selection guide and film-formation mechanism guide.
4. Which Variables Should Be Checked Before Choosing a Grade?
- Resin chemistry and OH value: calculate the NCO:OH starting point from the real resin and crosslinker data; do not use a universal fixed ratio.
- Deblocking temperature vs. oven profile: treat the published value as a screening reference, then validate PMT, dwell time and ramp behavior in the actual system.
- Catalyst compatibility: verify the catalyst in the exact resin/crosslinker system.
- Substrate and pretreatment: test the real tinplate, aluminum or other metal surface and film build.
- Downstream processing: repeat the actual forming, overcoating or colored-ink printing step.
- Finished regulatory requirement: validate food-contact suitability and migration performance on the finished packaging structure.
Deblocking temperature narrows the shortlist; the complete formulation and line profile decide whether it works.
5. Which Dongsen Blocked-Polyisocyanate Directions Are Worth Screening?
For can and coil coatings, these three grades represent different screening directions. They are lab starting points, not universal prescriptions.
| Grade | Chemistry | Solid % | Valid NCO % | Free NCO % | Viscosity @25°C | Deblocking | Carrier | Screening Direction |
|---|---|---|---|---|---|---|---|---|
| DXB-3375D | HDI Trimer | 75.0±2.0 | 11.2±0.5 | ≤0.2 | 2500±1000 cps | 130–140°C | Solvent Naphtha 100 | Aliphatic route for light-color can finishes and metal decorating; commercial evidence available. |
| DXTB-65D | TDI Polymer | 65.0±2.0 | 5.5±0.3 | ≤0.2 | 7000±3000 cps | 130–140°C | Solvent Naphtha 100 | Aromatic, cost-oriented route for darker systems; commercial can-coating evidence available. |
| DXB-3370G | HDI Trimer | 70.0±2.0 | 7.5±0.5 | ≤0.5 | Withheld pending TDS reconciliation | 80–100°C | PMA | Lower-deblocking screening route when the bake window requires it; PMT/dwell still needs validation. |
Table takeaway: DXB-3375D and DXTB-65D share a 130–140°C published deblocking range but differ in chemistry and active NCO; DXB-3370G shifts the screening reference to 80–100°C. All values are typical and subject to the current TDS/COA.
Explore the current blocked isocyanate category.

6. What Does Dongsen’s Metal-Packaging Experience Actually Show?
Can/container case: In a commercial aluminum/iron packaging project, DXB-3375D was adopted for the light-color series and DXTB-65D as a cost-oriented direction for darker products while replacing an imported blocked grade.
Tinplate metal-decorating case: In a separate commercial application, DXB-3375D was used in a baked coating. The recorded feedback included uniform appearance, stable deblocking, and colored-ink printing after baking without impairing ink adhesion.
These cases show commercial metal-packaging experience and a real post-bake printability check. They do not establish food-contact approval, PFAS compliance, migration compliance or retort performance.

7. Decision Tool: What Should You Screen First?
| Buyer Variable | Why It Matters | What to Verify | Direction to Screen |
|---|---|---|---|
| Color / appearance | Aliphatic and aromatic chemistry have different yellowing behavior. | Clear, white, light or dark system; heat/light requirement. | DXB-3375D for an aliphatic starting point; DXTB-65D for dark, cost-oriented systems. |
| Bake window | Deblocking temperature alone does not define production cure. | PMT, dwell time, ramp profile and film build. | Compare 80–100°C DXB-3370G with 130–140°C DXB-3375D/DXTB-65D as lab directions. |
| Resin OH / active NCO | Reactive balance affects network formation. | Resin OH value, valid NCO and formulation target. | Calculate from the actual formulation rather than using a universal ratio. |
| Carrier compatibility | Carrier choice affects the wet formulation package. | Solvent Naphtha 100 versus PMA compatibility. | 3375D / 65D use Solvent Naphtha 100; 3370G uses PMA. |
| Downstream printing | Decorative cans may require colored printing after bake. | Ink wetting and adhesion after the real bake cycle. | DXB-3375D has commercial tinplate evidence for post-bake colored-ink printing. |
| Food-contact requirement | Raw-material specs do not establish finished compliance. | Finished article, cure, migration/extraction protocol and market. | No grade should be selected on compliance grounds without finished-system validation. |
Decision-tool takeaway: use the table to choose what to test first, not to skip testing.
8. What Is the Next Test to Run?
- Compatibility: blend each candidate with the actual resin and solvent package; record clarity and stability.
- Cure-window screening: build a temperature/time ladder around the customer's real PMT and dwell range.
- Solvent resistance: use a recognized method such as ASTM D5402-19(2024) when appropriate. The method does not prescribe a universal solvent, double-rub count or pass/fail result, and solvent resistance alone does not prove full cure.
- Metal adhesion: use the customer's agreed method; ASTM D3359-23 is one recognized tape-test method for relatively ductile coatings on metallic substrates.
- Downstream process: repeat the actual forming, overcoating or printing sequence.
- Finished compliance: where food contact is involved, run the migration/extraction or other validation required for the complete package and market.
9. What Should You Send Before Asking for a Grade Recommendation?
- Resin chemistry and OH value.
- Current crosslinker and existing NCO:OH target or addition level.
- Actual PMT, dwell time and oven profile.
- Substrate, pretreatment and dry-film thickness.
- Catalyst type and addition level, if used.
- Color requirement and downstream forming / printing sequence.
- Destination market and finished food-contact requirement.
With these variables, Dongsen can suggest two to three candidate crosslinker directions for lab screening.
10. Key Takeaways
- PPWR sets PFAS concentration limits, not a blanket “remove every fluorinated material” rule.
- Blocked polyisocyanates are not PFAS replacements: they are one formulation variable for cure, adhesion and chemical resistance.
- Deblocking temperature is a screening reference, not PMT.
- Dongsen has commercial metal-packaging evidence for DXB-3375D and DXTB-65D, including a separate tinplate post-bake printing case for DXB-3375D.
- Food-contact compliance stays at finished-system level.
Dongsen is a licensed curing-agent manufacturer with its curing-agent production base in Shaoguan, China. It supplies polyisocyanate hardeners and crosslinkers as industrial raw materials, not finished can coatings, and its quality/environmental systems are certified to ISO 9001:2015 and ISO 14001:2015 under IAF mutual recognition. For EU/EEA/UK/CH/NO projects, Dongsen can receive technical inquiries and discuss screening samples where appropriate; no blanket claim of unrestricted REACH supply is made.
Related reading: Blocked Isocyanate Crosslinkers: Types, Deblocking Temperature & Selection Guide · Film Formation of Coatings: Mechanisms, Types & Factors · Isocyanate–Polyol Reaction & Hardener Selection · Dongsen Industries
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Send Your Can-Coating Screening Conditions
- Resin/OH-value check
- Deblocking-range shortlist
- PMT/dwell discussion
- Metal substrate and printing review
- TDS / sample / quotation follow-up
Frequently Asked Questions
Can blocked polyisocyanates directly replace PFAS in food packaging?
No. They are crosslinking agents, not fluorinated surface or barrier chemistries. The coating must be reformulated and validated as a complete system.
What PFAS limits apply from 12 August 2026?
PPWR Article 5(5) sets 25 ppb for any targeted PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for PFAS including polymeric PFAS.
Is deblocking temperature the same as production PMT?
No. Deblocking temperature is a screening property; PMT is the maximum temperature reached by the coated metal. Validate PMT and dwell time in the complete system.
What does the DXB-3375D tinplate case prove?
It shows a commercial tinplate application where colored ink was printed after baking without impairing ink adhesion. It does not prove food-contact approval, migration compliance or universal printability.
When should DXTB-65D be screened instead of DXB-3375D?
DXTB-65D is an aromatic TDI-polymer direction used in a dark-color can-coating route where cost mattered. DXB-3375D is the aliphatic HDI-trimer direction used as the main grade in that project and in a separate tinplate case.
Does Dongsen provide finished food-contact certification for these crosslinkers?
Dongsen supplies raw-material hardeners and crosslinkers with applicable TDS and COA. Finished food-contact suitability, migration performance and approval must be validated for the complete package and intended market.
Overseas Technical Support, Dongsen. Vicky works with international coating and adhesive formulators on waterbased and blocked polyisocyanate crosslinker selection, sample screening, and application troubleshooting. Connect on LinkedIn.