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. Since 12 August 2026 it has also restricted PFAS in food-contact packaging: 25 ppb for any individual targeted PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for PFAS including polymeric PFAS.
Updated 19 August 2026: revised now that the PPWR (Regulation (EU) 2025/40) applies, since 12 August 2026.
The Article 5 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 combined concentration of lead, cadmium, mercury and hexavalent chromium cannot exceed 100 mg/kg in any packaging unit. This limit carried over from the old packaging directive, so it is not new – what is new is having to evidence it in the technical file.
- PFAS are restricted in food packaging: the three Article 5(5) thresholds have applied to per- and polyfluoroalkyl substances in food-contact packaging since 12 August 2026, with no sell-through period for old stock.
- Contamination is a risk: inks, dyes, adhesives, and even recycled content can push your packaging over the legal limits.
- Proof is mandatory: both limits are demonstrated in the Annex VII technical file, which means laboratory results and supplier data, not assurances.
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.
Since 12 August 2026, food-contact packaging cannot be placed on the market if it contains PFAS at or above three thresholds. According to the EU Commission PPWR guidance document, testing follows a stepwise approach:
| PFAS Measurement Type | Maximum Concentration Limit |
|---|---|
| Individual PFAS, targeted analysis (polymeric PFAS excluded) | 25 ppb (parts per billion) |
| Sum of targeted PFAS (polymeric PFAS excluded) | 250 ppb (parts per billion) |
| PFAS including polymeric PFAS | 50 ppm (parts per million) |
Total fluorine sits outside that table, and the difference matters. A total-fluorine result above 50 mg/kg is a screening signal, not a verdict: it triggers a duty to provide, on request, proof of how much of that fluorine is PFAS and how much is not, so the manufacturer can complete the technical file. The detail is in our guide to PFAS in food packaging.
There is no transition period for exhausting old PFAS-containing stock. Food-contact packaging placed on the market since 12 August 2026 has to comply outright. To see how this fits the broader 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.
Under Annex VII of the regulation, 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 did the PFAS ban in food packaging take effect?
- The Article 5(5) restrictions on PFAS in food-contact packaging have applied since 12 August 2026, with no transition period for existing stock.
- 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.
- Where does heavy-metal contamination in packaging usually come from?
- Rarely from the core structure itself. Inks, dyes, pigments, coatings and adhesives used for branding and labels are the usual sources, along with poorly sorted recycled feedstock.
- What happens if my packaging tests high for total fluorine?
- A total-fluorine result above 50 mg/kg is a screening signal, not automatic non-compliance. It triggers a duty to show, on request, how much of that fluorine is PFAS and how much is not, so you can complete the technical file.
Reviewed by Anton Kröger