PPWR Restricted Substances: Heavy Metals and Article 5 Limits

If you ship physical products to EU customers, you are legally responsible for ensuring your boxes, mailers, and labels are safe. Article 5 of the new Packaging and Packaging Waste Regulation sets strict rules on what can be hidden inside your materials, placing clear boundaries on the use of harmful chemicals. Navigating the packaging heavy metals limits and the new bans on "forever chemicals" can feel overwhelming for a busy e-commerce operator. Here is exactly what the law requires and how to protect your business from compliance risks.

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.

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.

Understanding 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 Gram automate your packaging reports.

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:

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.

Practical impact and proving compliance

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 Gram.

Sources:

• Article 5 of the PPWR on restricted substances
• EU Commission PPWR guidance document
• SGS guidelines on packaging testing requirements