This page helps separate PPWR Article 5 substance minimisation, heavy-metal concentration limits, and the PFAS restriction for food-contact packaging.
The focus is the evidence a packaging team needs before placing packaging on the EU market, not a generic chemicals-policy overview.
Structured answer sets in this page tree.
Cited legal and guidance references.
Article 5 of Regulation (EU) 2025/40 sets the PPWR baseline for substances in packaging. It requires to be minimised in packaging materials and components, keeps the combined lead, cadmium, mercury, and hexavalent chromium limit at 100 mg/kg, and adds a PFAS restriction for food-contact packaging from 12 August 2026.
Article 5 is broader than the PFAS rule. It starts with a design and manufacturing requirement: in packaging material and packaging components must be minimised, including in emissions and waste-management outcomes such as secondary raw materials, ashes, or final-disposal materials.
For day-to-day compliance, split the review into three tracks: general , the combined heavy-metal concentration cap, and PFAS in food-contact packaging. That separation prevents teams from treating every substance issue as a PFAS-only question.
The heavy-metal rule applies to packaging or packaging components and caps the sum of lead, cadmium, mercury, and hexavalent chromium at 100 mg/kg. The rule sits alongside chemical restrictions under REACH and, where relevant, food-contact material rules.
The PFAS restriction is narrower: from 12 August 2026, food-contact packaging must not be placed on the market if it contains PFAS at or above any of the Article 5 limit values, unless another Union legal act already prohibits placing that packaging on the market.
The 100 mg/kg heavy-metal rule also has a limited derogation framework. Article 5 preserves the existing derogations for recycled glass packaging and plastic crates or pallets established under Commission Decisions 2001/171/EC and 2009/292/EC, and allows the Commission to amend those derogations through time-limited, case-specific delegated acts. Do not extend those derogations to other materials or formats.
Article 5(6) points teams to the PPWR technical documentation file. The evidence should prove which packaging components were assessed, which substance limits were relevant, what tests or supplier proofs were used, and who approved the market-placement decision.
Do not rely on a broad supplier statement that packaging is PPWR compliant. For Article 5, the defensible record should connect each claim to a component, material, analytical method, supplier document, or technical-documentation field.
This PPWR guide helps turn Article 5 substance limits into component-level evidence, supplier checks, and technical-documentation records.
The common error is to collapse Article 5 into a single headline ban. PPWR does not make every packaging substance question a PFAS question, and the PFAS limit values in Article 5 are tied to food-contact packaging.
The second error is ignoring overlap with other EU chemicals and food-contact regimes. Article 5 is drafted without prejudice to REACH restrictions and, where applicable, food-contact material measures, so a PPWR file should not be the only compliance check for chemicals in packaging.
Start with a component-level Article 5 register for packaging placed on the EU market. Mark whether each component is food-contact, whether PFAS screening is required, how the heavy-metal cap is evidenced, and where the technical-documentation proof is stored.
Then build procurement and change-control triggers around the materials most likely to affect Article 5: coatings, grease barriers, inks, adhesives, liners, fluorinated treatments, recycled inputs, and any supplier substitution that changes composition.
"PFAS will be banned from packaging from August 2026"
"By 31 December 2026, the Commission"