PPWR heavy metal limits: Article 5 in practice

The heavy metal limits in Article 5 of Regulation (EU) 2025/40 come down to one number: the combined concentration of lead, cadmium, mercury and hexavalent chromium may not exceed 100 mg/kg. This is not a limit per element. It is a limit on their sum. The requirement applies from 12 August 2026 and covers sales, grouped and transport packaging alike.

The second point to settle at the outset: the Regulation applies that limit to the packaging and to its components. In practice, one averaged figure for the whole pack is not enough. A component sitting at 400 mg/kg does not become compliant because it makes up 2% of the pack weight and dilutes itself in a weighted average. So the assessment runs on two tracks: you check each component, and only then, if you need a figure for the whole pack, you weight by mass.

A sum, not four separate limits#

The most common spreadsheet error: a limit column showing 100 next to each element and a green status because none of them exceeds it on its own. A test report showing Pb 20, Cd 15, Hg 5 and Cr(VI) 70 mg/kg is not a compliant result. It is 110 mg/kg and it is over the limit.

Three details that change the answer:

• It is hexavalent chromium that counts, not total chromium. A report giving "Cr" with no speciation does not answer the Article 5 question. If the laboratory reported total chromium, either go back and ask for Cr(VI) or, as a conservative assumption, treat the whole figure as Cr(VI) and check whether you are still inside the limit.
• The limit covers total content, not migration. That is a different question from migration testing on food contact materials. A migration report, however good, proves nothing about Article 5.
• The limit of quantification is not zero. A result of "less than 5 mg/kg" means the method cannot see below that. Across four elements, four such results can amount to 20 mg/kg on a conservative sum, and that is the figure worth recording in the documentation instead of a zero.

Calculating for multi-material packaging#

The arithmetic is simple, and what breaks it is almost never the calculation but a gap in the inputs. For each material, take its mass fraction, multiply by the measured sum of the four metals, and add the products together.

An example for a 198 g sales pack:

The figure for the whole pack looks calm: 44.7 mg/kg against a limit of 100. But the ink sits at 210 mg/kg and the ink is a component of the packaging. An assessment that stops at the weighted average misses a problem the authority will not miss. The correct conclusion from this table is: the result for the packaging is within the limit, but the ink and varnish component needs explaining — whether a derogation covers it, whether the data is right, whether the supplier has to change.

Where the data comes from#

The inputs come from four sources, listed here from the strongest evidence to the weakest:

1. A test report from an accredited laboratory for the specific material, with batch identification, the test method and Cr(VI) reported separately.
2. A supplier statement citing Article 5 of Regulation (EU) 2025/40 and the 100 mg/kg limit explicitly, with a date, an identification of the material and the batch, and a named signature.
3. A technical data sheet or material declaration with an unambiguous material designation, allowing literature data or type testing to be attributed.
4. A conservative assumption that you adopt and document — admissible where it shows that even the worst case stays inside the limit.

Suppliers of packaging materials are obliged to pass on to their customers the information needed for a conformity assessment (Article 16). This is not a polite request; it is a legal basis you can cite in correspondence. How to draft that request, and what disqualifies the document that comes back, is covered in the post on supplier documents.

Exclusions and derogations#

Derogations exist, but they are narrow and conditional. Two matter in practice:

• Glass packaging where the exceedance results from adding recycled glass cullet, with no intentional introduction of heavy metals in the production process. The condition is that the source is documented and the values are monitored.
• Plastic crates and pallets circulating in a closed, controlled loop where the material comes solely from the parties in that loop and the introduction of outside material is limited to a technical minimum. This derogation requires demonstrating that the loop really is closed — the fact that pallets come back is not enough.

The "empty field equals zero" trap#

This is the single most common reason a declaration cannot be defended. A spreadsheet does not distinguish missing data from a zero value — it sums the empty cells as zero and returns a result that looks compliant. But the absence of data on a material making up 15% of the pack weight is not information that the material is clean. It is information that you do not know.

A working rule worth putting into the procedure: until a component has evidence, the packaging carries the status "incomplete", not "compliant with reservations". To see how that looks on your own items, break one pack down into materials and calculate the sum — the first surprise usually involves inks, adhesives and labels, the components with the smallest mass and the weakest documentation.

Substances of concern and PFAS#

Article 5 does not stop at heavy metals. The Regulation requires the presence of substances of concern in packaging materials and components to be minimised, and requires that those substances do not impede recycling or carry over into recycled materials. The technical documentation should show that the question was analysed: which substances were identified, on what basis, and what was done about them.

PFAS in food contact packaging are regulated separately. From 12 August 2026, such packaging may not be placed on the market if it contains PFAS at or above the thresholds set in Article 5:

Total fluorine works as a screening test: it is cheaper than full targeted analysis and lets you filter out materials that need no further work. That stepwise approach — total fluorine first, then confirmation that the fluorine is organic, then precursor analysis — is exactly what the Commission guidance of June 2026 recommends, while noting that no harmonised EU methodology for testing PFAS in food-contact packaging exists. The usual candidates for screening are paper and board with grease-barrier coatings, baking moulds, fast-food packaging and some non-stick coatings.

What ends up in the declaration#

One sentence about meeting the requirements of Article 5 goes into the declaration of conformity. Everything above — the values, the sources, the assumptions, the calculations and the justification for any derogation — belongs in the technical documentation you make available to the authority on request. How to connect the two, and what not to write into the declaration itself, is covered in the post on how to issue a packaging declaration of conformity. If you are unsure whether your company is the one that should sign it, check who the PPWR applies to.