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PPWRArticle 5 guideEU

PPWR Article 5 PFAS and restricted substances

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.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
5 sections2 primary sources
Overview

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.

Section 1

What does Article 5 cover?

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.

  • Identify each packaging material and component, including coatings, inks, adhesives, barriers, labels, closures, and liners.
  • Record which are present and how the design minimises their concentration and downstream impact.
  • Test the combined concentration of lead, cadmium, mercury, and hexavalent chromium against the 100 mg/kg Article 5 cap.
  • For food-contact packaging, screen PFAS against the Article 5 limit values that apply from 12 August 2026.
  • Keep the Article 5 evidence in the technical documentation required for PPWR conformity.
Section 2

What are the Article 5 limit values?

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 70(3) 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 Article 5(8) allows the Commission to amend those derogations through time-limited, case-specific delegated acts. Do not extend those derogations to other materials or formats.

  • 100 mg/kg for the combined concentration of lead, cadmium, mercury, and hexavalent chromium in packaging or packaging components.
  • 25 ppb for any PFAS measured with targeted PFAS analysis, excluding polymeric PFAS from quantification.
  • 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors and excluding polymeric PFAS from quantification.
  • 50 ppm for PFASs including polymeric PFAS.
  • If total fluorine exceeds 50 mg/kg, suppliers in the chain may need to provide proof of the quantity measured as PFAS or non-PFAS so manufacturers or importers can prepare technical documentation.
  • Apply a heavy-metal derogation only to the recycled material or controlled product loop covered by the relevant Commission decision or later delegated act, with its marking, information, and reporting conditions.
Section 3

How should teams evidence compliance?

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.

  • Packaging bill of materials with components, materials, suppliers, and food-contact status.
  • Substance-of-concern review showing how concentrations were minimised and where substitution was considered.
  • Heavy-metal test evidence or supplier declarations covering lead, cadmium, mercury, and hexavalent chromium.
  • PFAS test reports for food-contact packaging, including targeted PFAS analysis and any total-fluorine follow-up.
  • Supplier proof distinguishing PFAS and non-PFAS fluorine when total fluorine exceeds the Article 5 trigger.
  • Technical-documentation index showing where Article 5(4) and Article 5(5) compliance evidence is stored.
  • Change-control record for coatings, inks, adhesives, barriers, recycled inputs, and supplier substitutions.
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Section 4

Where do teams usually misread the rule?

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.

  • Do not apply the Article 5 PFAS thresholds to non-food-contact packaging unless another rule or product requirement creates that need.
  • Do not treat the 100 mg/kg heavy-metal cap as four separate 100 mg/kg limits; Article 5 refers to the sum of the four listed substances.
  • Do not publish a blanket PFAS-free claim unless the test method, component scope, and polymeric PFAS treatment support that wording.
  • Do not assume recycled material is outside Article 5; the minimisation requirement explicitly considers waste-management outcomes and secondary raw materials.
  • Do not cite old PPWR proposal text when the adopted Regulation (EU) 2025/40 is available for the binding Article 5 wording.
Section 5

What should teams do next?

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.

  • Ask suppliers for component-specific substance disclosures rather than packaging-family statements.
  • Require test reports to name the packaging component, method, date, and whether polymeric PFAS were included or excluded.
  • Map Article 5 evidence to the technical-documentation owner before launch approval.
  • Schedule a review for Commission follow-up on and the 2030 PFAS overlap evaluation.
  • Keep public claims narrower than the evidence: say what was tested, for which components, against which PPWR Article 5 threshold.
Primary sources

References and citations

Regulation (EU) 2025/40 on packaging and packaging waste
data.europa.eu6 citations
Referenced sections
  • Binding Article 5 source for substances of concern, heavy-metal concentration limits, PFAS limit values for food-contact packaging, and technical-documentation evidence.
  • Article 5(1) supports the page scope by requiring minimisation of substances of concern in packaging materials and components.
  • Articles 5(4), 5(8), and 70(3) provide the 100 mg/kg combined heavy-metal concentration cap, the limited framework for recycled-material or closed-and-controlled-chain derogations, and preservation of the existing Commission Decisions; Article 5(5) provides the food-contact PFAS limits and date.
Show 3 more
  • Article 5(5)(c) states the total-fluorine proof rule, and Article 5(6) requires evidence for the heavy-metal and PFAS limits in PPWR technical documentation.
  • Article 5(4) supports treating the listed heavy metals as one combined concentration limit, while Article 5(5) limits the PPWR PFAS threshold rule to food-contact packaging.
  • Article 5(2) sets the Commission reporting and follow-up process for substances of concern, and Article 5(5) requires an evaluation by 12 August 2030 of possible overlap with other EU PFAS restrictions.
"Requirements for substances in packaging"
More quoted passages
"the presence and concentration of substances of concern"
"shall not exceed 100 mg/kg"
"shall be demonstrated in the technical documentation"
"the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium"
"By 31 December 2026, the Commission"
Packaging & Packaging Waste Regulation
environment.ec.europa.eu
Referenced sections
  • European Commission PPWR overview used only for high-level context on the regulation's application and PFAS measure, not as a substitute for Article 5 text.

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