PFAS-Free Paper Packaging in the GCC: Food-Contact Rules for Hot, Oily Foods (2026)

Introduction

Paper boxes and bags for biryani, shawarma and grilled meats have to cope with heat, free fat and steam while still meeting food-contact safety rules. Brands supplying the GCC therefore need to know which Gulf and national instruments govern paper packaging, and what those instruments do and do not say about PFAS.

The EU’s PFAS limits for food-contact packaging under Regulation (EU) 2025/40, which apply from 12 August 2026,^[1] are the obvious comparison point. This guide sets out the GCC requirements, the evidence to ask suppliers for, and where the current rules stop. Part 2 reviews the research on fat migration through PFAS-free paper.

What PFAS-Free Paper Packaging Means for Food Contact

Defining PFAS and why they are used in paper

Per- and polyfluoroalkyl substances (PFAS) are fluorinated chemicals built on strong carbon–fluorine bonds. In paper, fluorinated treatments supply the water and grease repellency that untreated fibre lacks. Food packaging accounts for roughly a third (about 33% by weight) of European production of fluorinated compounds.^[2]

Why intentionally added PFAS are being phased out of food-contact paper

Most of the debate concerns PFAS added deliberately as grease barriers. From 12 August 2026, Regulation (EU) 2025/40 limits PFAS in food-contact packaging placed on the EU market.^[1] The limits are concentrations, so a supplier statement that PFAS are “not intentionally added” does not on its own prove compliance.^[3]

Why oil-rich, heat-served foods are the hard case

Biryani, shawarma, grilled meats and fried foods combine free fat, steam and long hold times. Heat also raises the chemical-transfer risk. In a 2022 study of six PFAS-treated paper food-contact materials used at high temperature, PFCAs and fluorotelomer alcohols (FTOHs) migrated into all three real foods tested. The estimated PFAS exposure for children (1.06–5.67 ng/kg bw per day) exceeded the EFSA-derived threshold of 0.63 ng/kg bw per day used by the authors, by up to about nine times.^[4] For food product development teams, the pack is therefore a specified component, not an afterthought.

The GCC Food-Contact Material Framework

GSO technical regulations and member-state rules

The GCC framework is layered: Gulf (GSO) technical regulations first, national conformity schemes second. GSO 2231:2012, approved on 3 October 2012, applies to all materials and articles intended to come into contact with food and includes labelling and traceability requirements.^[5] GSO 839:2021 (edition 2, approved 1 July 2021) sets general requirements for all food packages, including paper and carton.^[6]

In the UAE, food-contact materials, paper included, are certified under the UAE Conformity Assessment Scheme (ECAS) against the technical requirements of Cabinet Resolution No. 20 of 2015.^[7] In Saudi Arabia, the SFDA lists SFDA.FD/GSO 839 and SFDA.FD/GSO 1863 as its food-packaging requirements.^[8]

How PFAS and migration limits are treated

None of the GSO, SFDA or MoIAT sources reviewed for this article (checked October 2026) sets a PFAS limit for food-contact paper. On 11 June 2026, the SFDA announced that its Dammam reference laboratory had been accredited for a method that monitors more than 20 PFAS in foods and related materials, including food packaging.^[9] That is testing capacity, not a limit. The public entries for the GSO regulations also state no overall migration limit specific to paper.

For comparison, the EU applies 25 µg/kg (25 ppb) for any single PFAS, 250 µg/kg for the sum of PFAS and 50 mg/kg (50 ppm) for total PFAS, including polymeric PFAS, from 12 August 2026.^[1][3] FRL’s overview of sustainable packaging engineering in the EU covers the wider EU packaging context.

Table 1. GCC food-contact requirements for paper packaging, with the EU as comparator (checked October 2026)

FRL’s regulatory research team can check supplier declarations, migration reports and total-fluorine results against Table 1 for each target market.

What the Rules Require for Oil-Rich, Heat-Served Foods

Migration testing and overall migration limits

Migration means substances moving from the packaging into the food. With no paper-specific EU migration rule, the 2022 study above adapted test conditions from the EU plastics rules and used 50% and 20% ethanol as food simulants.^[4] Migration of PFCAs and FTOHs into 50% ethanol was significantly higher than into the real foods (oatmeal porridge, muffins and tomato soup), while FTOHs did not migrate into 20% ethanol at all, although they did migrate into all three foods.^[4] Simulant conditions written for plastics therefore cannot be assumed to represent every PFAS group in paper.

Because the public GCC entries do not specify simulants or contact conditions for paper, the laboratory report should state the temperature, time and simulant chosen, and why. FRL’s article on migration testing for packaging explains how these conditions are set.

Grease and oil resistance expectations

Oil and grease resistance is a performance property, not a legal limit. None of the GSO, SFDA, MoIAT or EU sources above sets a minimum grease-resistance value. Test methods exist, such as the kit test (TAPPI T 559) for surface repellency,^[2] but a method is not a limit. The pass threshold therefore has to come from the buyer’s specification and should be written into the purchase agreement.

What a compliant declaration does and does not cover

A declaration of compliance states that the material meets the applicable PFAS and migration limits. It does not show that a box will hold hot, oily food: migration limits govern what moves into the food, while grease holdout governs what moves through the board. EU guidance treats a total-fluorine result below 50 mg/kg as a basis for considering a sample compliant, while noting that there is no harmonised EU test method,^[3] and no fluorine result predicts oil strike-through. Keep the two proofs in separate files.

PFAS-Free Barrier Options and Their Trade-offs

PFAS-free options for grease-resistant paper include bio-based coatings such as PLA, starch, chitosan, lignin, whey protein and alginate, and waxes.^[10] Producing biopolymers costs about USD 4,000–15,000 per tonne, against an average of about USD 1,500 for synthetic polymers.^[10] FRL’s guide to reformulating food for compostable packaging discusses a fluorine-free chitosan lining for moulded-pulp meal boxes.

Shorter-chain (≤C6) fluorinated chemistries are still fluorinated,^[2] so they remain within the scope of the EU concentration limits.^[1] The Regulation sets no separate PFAS allowance for recycled content, which matters for any recycled-fibre paperboard supply chain.^[1] Performance evidence for these barriers under hot, oily food is reviewed in Part 2; shelf-life effects of alternative packs are covered in FRL’s article on biodegradable packaging shelf life in the UAE.

Compliance Pathway: Testing, Documentation and Labelling

In the UAE, certification runs through MoIAT’s conformity scheme: a valid test report from an accredited, recognised laboratory, GMP compliance and an electronic declaration of conformity, with up to 45 SKUs per certificate.^[7] GSO 2231 adds labelling and traceability requirements across the GCC.^[5]

For PFAS, the European Commission’s guidance describes a stepwise approach: screen total fluorine first; if the result is above 50 mg/kg, use a method such as pyrolysis-GC/MS to confirm whether the fluorine is organic; and use direct total oxidisable precursor (dTOP) analysis to check the 25 and 250 µg/kg limits.^[3]

Ask every paper supplier for five documents:

• the declaration of compliance;
• a total-fluorine report;
• migration reports that state temperature, time and simulant;
• a separate grease-holdout report;
• labelling and traceability records.

Practical Checklist for Brands Switching to PFAS-Free Paper

1. Map each SKU to its target markets and to the instruments in Table 1.
2. Obtain total-fluorine results for every paper component and keep the exact wording of any PFAS-free claim.^[3]
3. Collect migration reports that match the real contact temperature, time and food, and reject reports run only under dry-food conditions.^[4]
4. Set a minimum grease-holdout specification and test it separately from compliance.
5. Lock the pack into food product development gates before artwork and launch.
6. Re-check every six months, because EU and GCC positions are still moving.

Part 2 covers the fat-migration evidence behind check 4.

Worked Example: Assessing a Paper Biryani Box for the UAE and Saudi Arabia

This is an illustrative application of FRL’s assessment framework, not a completed client study, and it reports no test results.

Brief

A brand plans a paper-based biryani box for hot, oily food in the UAE and Saudi Arabia. The supplier’s EU-oriented PFAS-free declaration covers PFAS limits only. It does not show grease holdout or GCC food-contact compliance.

Approach

The framework first identifies the exact paper and barrier, since “PFAS-free” does not mean uncoated. It then checks the supplier declaration and test reports against UAE and Saudi requirements, and treats migration as two questions: substances moving into the food, and fat moving through the board (strike-through).

• Market-specific compliance: check documents against GSO 2231, GSO 839, UAE MoIAT and SFDA requirements, and record where no PFAS limit is named.
• Chemical assessment: screen total fluorine first; if it is above 50 mg/kg, confirm with pyrolysis-GC/MS, then use dTOP against the 25 and 250 µg/kg EU limits.^[3]
• Migration testing: match the simulant, temperature and time to actual use, and reject reports run only under dry-food conditions.
• Grease resistance: use a separate protocol. The kit test shows surface repellency,^[2] ISO 16532-1 measures grease permeability,^[11] and a hot-oil hold test on the folded box covers seams and creases. The Cobb test measures water absorption, not fat.
• Regulatory verification: confirm the GSO and national requirements against the full texts before release.

Outcome

The framework identifies documentation gaps, sets the tests needed and defines a separate pass criterion for grease holdout. Suitability is decided only after the regulations, supplier evidence and test results have been reviewed together.

Formulator’s note: treat the pack as an ingredient. Free oil, filling temperature and hold time decide what the pack experiences. Record all three for each hot, oily SKU before asking a supplier for a PFAS-free option, and put them in the specification. A declaration written for a dry snack will not protect a biryani box.

Conclusion

No GCC instrument reviewed sets a PFAS limit for food-contact paper, but GSO 2231, GSO 839 and the UAE and Saudi conformity routes still apply, and EU exporters must meet the 2025/40 limits. For hot, oily foods, compliance needs two separate proofs: documented chemical safety with migration testing that matches real use, and grease holdout under the intended conditions. Building both into development early catches packaging risks before launch.

For Brands & Formulators: Checking PFAS-Free Paper Packs for the GCC

If you are switching a hot, oily SKU to PFAS-free paper for the UAE, Saudi Arabia or the wider GCC, FRL’s scientific and regulatory research team can review your supplier’s declaration, total-fluorine and migration reports against GSO 2231, GSO 839, MoIAT and SFDA requirements and the EU limits, list the gaps and specify the extra tests, including a separate grease-holdout protocol for the folded pack. Our food packaging team can then align the pack with your product and launch artwork.

Request a packaging declaration review or talk to our team.

1. European Parliament & Council of the European Union. (2025). Regulation (EU) 2025/40 of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. Official Journal of the European Union, L, 22 January 2025. https://eur-lex.europa.eu/eli/reg/2025/40/oj
2. Guzman-Puyol, S. (2024). Fluorinated compounds in paper and paperboard based food packaging materials. npj Science of Food, 8, Article 82. https://doi.org/10.1038/s41538-024-00326-2
3. European Commission. (2026). Commission notice: Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste (C/2026/3084). Official Journal of the European Union, C, 10 June 2026. https://eur-lex.europa.eu/eli/C/2026/3084/oj
4. Lerch, M., Nguyen, K. H., & Granby, K. (2022). Is the use of paper food contact materials treated with per- and polyfluorinated alkyl substances safe for high-temperature applications? Migration study in real food and food simulants. Food Chemistry, 393, Article 133375. https://doi.org/10.1016/j.foodchem.2022.133375
5. GCC Standardization Organization. (2012). General requirements for the materials intended to come into contact with food (GSO 2231:2012) [Gulf technical regulation, approved 3 October 2012]. https://www.gso.org.sa/store/standards/GSO:589298/GSO%202231:2012?lang=en
6. GCC Standardization Organization. (2021). Food packages – Part 1: General requirements (GSO 839:2021) [Gulf technical regulation, edition 2, approved 1 July 2021]. https://www.gso.org.sa/store/standards/GSO:780890/GSO%20839:2021?lang=en
7. Bureau Veritas. (2023). MoIAT service cards: Service card for food contact material [Service card, February 2023]. https://cdn3-verigates.bureauveritas.com/sites/verigates/files/2023-02/AE%20-%20MoIAT%20Service%20Cards%2009022023.pdf
8. Saudi Food and Drug Authority. (2024). What are the requirements of food product packaging? [FAQ; last updated 18 July 2024]. https://www.sfda.gov.sa/en/faq/88889
9. Saudi Food and Drug Authority. (2026, June 11). SFDA achieves a Middle East first as Dammam Reference Laboratory earns accreditation for PFAS monitoring in food [News release]. https://www.sfda.gov.sa/en/news/5521947
10. Rozas, B., Bruna, J. E., Guarda, A., Galotto, M. J., Reyes, C., Valenzuela, X., Rodríguez-Mercado, F., & Torres, A. (2025). Bio-based coatings on cellulosic materials resistant to humidity and fats. Polymers, 17(20), Article 2755. https://doi.org/10.3390/polym17202755
11. International Organization for Standardization. (2008). Paper and board: Determination of grease resistance: Part 1: Permeability test (ISO Standard No. 16532-1:2008). https://www.iso.org/standard/37980.html