PPWR Restricted Substances: Heavy Metals and Article 5 Limits
What Article 5 restricts, where contamination usually creeps in, and how to prove compliance
Article 5 of the PPWR caps the combined concentration of lead, cadmium, mercury and hexavalent chromium at 100 mg/kg in any packaging unit. From 12 August 2026 it also restricts PFAS in food-contact packaging: 25 ppb for any individual PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm of total fluorine.
These limits rarely come from the box itself. They come from inks, dyes, coatings, adhesives, and poorly sorted recycled feedstock.
Key takeaways
- Heavy metals are capped: The total concentration of lead, cadmium, mercury, and hexavalent chromium cannot exceed 100 mg/kg in any packaging unit.
- PFAS are banned in food packaging: Strict new limits apply to per- and polyfluoroalkyl substances in food contact packaging starting 12 August 2026.
- Contamination is a risk: Inks, dyes, adhesives, and even recycled content can push your packaging over the legal limits.
- Proof is mandatory: You need laboratory test reports and comprehensive supplier data to legally sell your packaged products.
What is the minimisation duty for substances of concern?
Before diving into specific chemical limits, it is vital to understand the broader goal of the new EU regulation. Article 5 dictates that all packaging must be manufactured so that the presence and concentration of substances of concern are minimised. This covers emissions, outcomes of waste management, and even the adverse impact on the environment due to microplastics.
As an online seller, you must ensure that your packaging design avoids unnecessary toxicological risks. This is not just a suggestion, but a binding rule outlined in Article 5 of the PPWR. The objective is to ensure that packaging, and the secondary raw materials recycled from it, do not have adverse effects on human health or the environment.
What are the packaging heavy metals limits?
The most immediate and concrete restriction applies to four specific heavy metals. The sum of the concentration levels of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg, which is equivalent to 100 parts per million by weight.
The 100 mg/kg threshold applies to all packaging placed on the EU market, meaning your entire packaging unit must be tested and verified to remain below this limit.
Heavy metals rarely make up the core structure of a cardboard box or a plastic mailer. Instead, they often hide in the supplementary components. You need to be particularly vigilant about inks, dyes, pigments, coatings, and adhesives used for branding and labels. Furthermore, contamination can easily creep in through recycled content, especially if the recycled feedstock was poorly sorted. You must verify these limits with your suppliers as you build your PPWR technical documentation.
To avoid fines and product delistings, having a structured approach to compliance is critical. If you are tired of chasing suppliers for data, let Gramta automate your packaging reports.
What is the PFAS ban for food contact packaging?
If you sell food or beverages, the rules are even stricter. Per- and polyfluoroalkyl substances, commonly known as PFAS or forever chemicals, have historically been used to create grease-resistant coatings on paper cups, fast food wrappers, and pizza boxes. Due to their persistence in the environment and risks to human health, the EU has introduced aggressive restrictions.
From 12 August 2026, food contact packaging cannot be placed on the market if it contains PFAS at or above specific thresholds. According to the EU Commission PPWR guidance document, testing should follow a stepwise approach to ensure materials do not exceed these limits:
| PFAS Measurement Type | Maximum Concentration Limit |
|---|---|
| Individual PFAS (targeted analysis) | 25 ppb (parts per billion) |
| Sum of targeted PFAS | 250 ppb (parts per billion) |
| Total fluorine (including polymeric PFAS) | 50 ppm (parts per million) |
Unlike some other environmental rules, there is no transition period for the exhaustion of old stock containing PFAS. Food contact packaging placed on the market after the August 2026 deadline must comply entirely, meaning you must audit your supply chain well in advance. To see how this fits into the broader regulatory picture, review the full PPWR compliance timeline.
How do you prove compliance with Article 5?
You cannot simply assume your packaging is safe. Regulatory authorities require concrete proof. To demonstrate compliance, you must gather and retain a comprehensive technical file for every packaging format you use.
As highlighted by SGS guidelines on packaging testing requirements, your technical documentation must include a complete bill of materials covering all components like inks and adhesives. You will also need laboratory test reports that confirm your materials sit below the heavy metal and PFAS thresholds.
Once you have gathered this evidence, you must draft an EU Declaration of Conformity. This document is a formal legal statement confirming your packaging meets all sustainability requirements. Before you sign the PPWR Declaration of Conformity, you must be absolutely certain your supplier data is accurate and verifiable.
If managing chemical thresholds, supplier certificates, and ever-changing EU regulations is slowing down your business growth, let our software handle the complexity. Start automating your packaging compliance with Gramta.
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Frequently asked questions
- What is the packaging heavy metals limit under PPWR?
- The combined concentration of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg in any packaging unit.
- When does the PFAS ban in food packaging take effect?
- The restrictions on PFAS in food contact packaging apply from 12 August 2026.
- How do I prove compliance with Article 5?
- You must hold technical documentation, including laboratory test reports and a bill of materials, to back up your Declaration of Conformity.
Reviewed by Anton Kröger