What are the packaging substance restrictions under PPWR Article 5?

Article 5 of the Packaging and Packaging Waste Regulation sets strict limits on hazardous chemicals in packaging across the European Union. It caps lead, cadmium, mercury and hexavalent chromium at a combined 100 mg/kg in any packaging or component, and has banned PFAS above set thresholds in food-contact packaging since 12 August 2026.

Selling packaged goods into Europe means facing a changing chemical landscape under Article 5 of the PPWR. Historically, sellers only had to worry about basic safety limits, but the new framework drastically tightens what is allowed to touch your products and eventually enter the recycling system or the environment. The rules shift the focus from merely containing products to ensuring that the materials themselves do not contaminate the recycling loop or harm human health.

For merchants, Article 5 means a much closer relationship with your packaging suppliers. You can no longer assume a standard cardboard box or plastic wrapper is legally sound just because it was cheap to procure. The responsibility now includes verifying the exact chemical makeup of the materials you use, especially if your items come into direct contact with food or beverages. Navigating these requirements requires careful supply chain auditing and clear documentation.

What PPWR Article 5 actually means

Under the Packaging and Packaging Waste Regulation (PPWR), Article 5 dictates that all packaging placed on the market must be manufactured so that the presence and concentration of substances of concern are minimised (Packaging and Packaging Waste Regulation (EU) 2025/40). The primary goal is to prevent these chemicals from affecting recycling processes, ending up in secondary raw materials, or creating adverse environmental impacts through emissions or waste disposal. This is not just a vague guideline; the law imposes rigid numerical limits on specific substances to protect both human health and the environment.

For example, the total concentration of lead, cadmium, mercury, and hexavalent chromium in any packaging or packaging component must not exceed 100 mg/kg. There is also a major crackdown on per- and polyfluoroalkyl substances (PFAS) in packaging designed for food contact. Since 12 August 2026, food-contact packaging containing PFAS above the Article 5(5) thresholds cannot be placed on the market. These substances, often called forever chemicals, have historically been used to make paper and cardboard resistant to grease and water, which is incredibly common in the takeaway and grocery sectors.

Compliance with the requirements for heavy metals and PFAS limits must be demonstrated in the technical documentation drawn up in accordance with Annex VII.

The Article 5 technical documentation acts as your legal shield. If a market surveillance authority requests proof of compliance, you must be able to produce the chemical breakdowns from your suppliers showing that your packaging materials fall below the required thresholds. You cannot wait for an audit to start asking your manufacturers for this data; it must be gathered and maintained before the items cross the border.

Does this apply to me?

If you are a manufacturer or importer placing packaging on the European Union market, these Article 5 substance restrictions apply directly to you. Whether you sell a simple plastic toy in a blister pack or fresh produce wrapped in film, the packaging must comply with the minimisation of substances of concern and the heavy metal limits.

The tightest restrictions, however, apply to food-contact packaging. The strict limits on PFAS apply specifically to packaging that is intended to be brought into contact with food (Commission Notice - Guidance document for Regulation (EU) 2025/40 on packaging). The rules bite on packaging placed on the market from the effective dates. There was no transitional period for exhausting stocks of food-contact packaging containing PFAS produced before 12 August 2026, so anything you place on the market now must comply.

Non-compliant packaging placed on the market before 12 August 2026 does not need to be withdrawn, which means the deciding question for any remaining inventory is whether it was already placed on the market before that date.

What concentration limits does PPWR Article 5 set for heavy metals and PFAS?

The limits and thresholds under Article 5 are exact maximum concentrations for specific hazardous chemicals. Sellers must ensure their packaging materials do not exceed these legal limits.

For the 50 ppm limit on PFASs, if the total fluorine content exceeds 50 mg/kg, the economic operator must provide proof of the quantity of fluorine measured as either PFAS or non-PFAS. This is required so the manufacturer or importer can properly draw up the technical documentation. Gathering this proof often requires engaging specialised testing laboratories to verify the exact chemical composition of the materials.

Common misconceptions about PPWR Article 5

“I can just sell through my old non-compliant stock indefinitely”

Packaging placed on the market before 12 August 2026 does not need to be recalled, but that date has passed, so old stock containing restricted PFAS can no longer be placed on the market at all. The moment of placing on the market is the trigger, and non-compliant inventory still sitting in your warehouse cannot legally leave it for the EU market.

“These rules only apply to plastic packaging”

The heavy metal limits apply to all packaging and packaging components, regardless of the material. Whether you use cardboard, glass, metal, or plastic, the total concentration of lead, cadmium, mercury, and hexavalent chromium remains capped. Do not assume a material is exempt just because it is not plastic.

“My supplier's verbal assurance is enough”

You cannot rely on a simple promise from your packaging manufacturer. The regulation requires formal technical documentation to demonstrate compliance. If you face an audit, you need actual test results, certificates of analysis, or verifiable chemical composition data to prove your claims.

4 examples of Article 5 impacts on merchants

Switching fast-food wrappers

A seller of takeaway meals previously used grease-resistant paper coated with PFAS. Since 12 August 2026 that packaging cannot be placed on the market, so the seller has to source alternatives built on natural barriers or non-fluorinated coatings, and test them for performance and safety.

Auditing glass suppliers

A cosmetics brand importing glass jars must verify that the heavy metal content in the glass - specifically lead and cadmium - remains under the combined limit. They must request updated certificates of analysis from their overseas glass manufacturer to include in their technical files.

Re-evaluating recycled plastics

A brand using post-consumer recycled plastic for food containers must ensure that the recycling process has not inadvertently introduced restricted substances of concern into the new packaging. This demands stricter sorting and processing guarantees from their recycling partners to maintain material purity.

Halting sales of old inventory

A merchant holding a warehouse of imported food cartons treated with restricted chemicals cannot place them on the European market now that the cut-off date has passed. Whatever was not already placed on the market before 12 August 2026 is a stranded asset for the EU and has to be redirected or written off.

Terms related to PPWR Article 5 (requirements for substances of concern)

Frequently asked questions

When did the PFAS restrictions take effect?

The restrictions on PFAS in food-contact packaging have applied since 12 August 2026. Any food-contact packaging placed on the market from that date must comply with the concentration limits in Article 5(5).

Do I have to recall packaging that is already on the market?

No. Packaging that was placed on the market before 12 August 2026 can remain there and does not need to be withdrawn. The regulation includes no transitional period for exhausting stocks, so the only thing you cannot do is introduce further non-compliant stock now that the date has passed.

What are the exact limits for heavy metals in my packaging?

The sum of the concentrations of lead, cadmium, mercury, and hexavalent chromium present in your packaging or its components must not exceed 100 mg/kg. This applies to all packaging materials, not just plastics.

How do I prove that my packaging does not contain these substances?

You must compile technical documentation in accordance with Annex VII of the regulation. This file should contain the necessary evidence, such as material composition breakdowns or test results, to demonstrate that the packaging meets the chemical restrictions.

Are there any exemptions for recycled materials?

The European Commission has the power to adopt delegated acts to determine specific conditions where the heavy metal concentration limits might not apply to recycled materials or product loops in a closed and controlled chain. However, as a general rule, the restrictions apply across the board to minimise environmental contamination.

Sources:

• Packaging and Packaging Waste Regulation (EU) 2025/40
• Commission Notice - Guidance document for Regulation (EU) 2025/40 on packaging