PFAS and heavy metals in packaging: limit values, testing route and evidence under Article 5 PPWR

Of all the requirements of the EU Packaging Regulation, Article 5 is the only one that has applied since 12 August 2026 without any transitional period and where exceeding a limit immediately means that the packaging may not be placed on the market. Labelling follows in 2028 and the recyclability grades in 2030; the substance limits apply today.

This is particularly awkward for PFAS in food-contact packaging, because there is neither a list of the substances concerned nor a harmonised test method, but there is a testing route that the Commission recommends to the market surveillance authorities, and you should know it before an authority applies it.

This article explains both limit values, the testing route, how evidence is provided in the technical documentation and the exemptions for recycled glass and reusable crates. At the end there is a testing plan to download.

Three levels in one article

Article 5 contains three different requirements that are often mixed up in practice.

Minimisation of substances of concern (paragraph 1). A general obligation to keep the content of substances of concern in packaging material and packaging components as low as possible. No numerical value, but a statement that belongs in the technical documentation.

Heavy metal limit (paragraph 4). The sum of the concentrations of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg. This applies to all packaging, regardless of material and use.

PFAS limits (paragraph 5). Since 12 August 2026, food-contact packaging may no longer be placed on the market if it contains PFAS above the limit values. This concerns food contact only, but applies there without exception.

For the limit values in paragraphs 4 and 5, paragraph 6 expressly requires compliance to be demonstrated in the technical documentation under Annex VII; minimisation under paragraph 1 belongs there as well, because Annex VII covers conformity with all applicable requirements of Articles 5 to 12. Without this evidence the declaration of conformity is not robust, even if the values are in order.

The heavy metal limit

The value of 100 mg/kg is familiar from the old Packaging Directive and has not changed. Two things about it are regularly misunderstood.

It applies to the sum, not to each metal. Lead, cadmium, mercury and hexavalent chromium are added together. A board material with 40 mg/kg lead and 70 mg/kg chromium VI exceeds the limit, even though no individual value would stand out.

It applies to the packaging unit including printing inks, varnishes and adhesives. The Commission has expressly clarified this in its FAQ. The material data sheet for the board alone is therefore not enough; anyone who tests only the substrate is testing the wrong object. For data collection this means that printing ink, varnish, adhesive, label and coating are separate items with their own values. How to request this in a structured way is explained in Model letter to upstream suppliers.

The limit also applies "without prejudice" to the restrictions under Annex XVII to the REACH Regulation and the rules on food contact materials under Regulation (EC) No 1935/2004. Where those are stricter, they take precedence. Article 5 is an additional threshold, not an upper limit for everything.

The exemptions. For recycled glass, Commission Decision 2001/171/EC continues to apply: exceeding 100 mg/kg is permitted if it results from the use of recycled glass. Intentionally introducing the four metals remains prohibited. For plastic crates and pallets made from recycled material, the earlier EU exemption also continues to apply (Decision 2009/292/EC, still applicable under Article 67(3) of the Regulation); in Germany the conditions are laid down in Sections 14 to 18 VerpackDG: they may exceed the limit if the exceedance results solely from the secondary raw material, the packaging circulates in closed and controlled loops, an inventory and control system is in place, a return rate of at least 90 per cent is achieved and the company placing them on the market maintains its own declaration of conformity together with an annual report. Both exemptions lapse as soon as the Commission repeals the underlying decisions by delegated act under Article 5(8). What this means for pallet pools is explained in Does the PPWR apply to B2B? Transport packaging, pallets and cartons.

The Commission can lower the value in future by delegated act and lay down the conditions for exemptions in closed loops (paragraphs 7 and 8). Neither has happened yet.

The PFAS limit values

For packaging that comes into contact with food, three values have applied side by side since 12 August 2026:

There is also a duty to provide information that many overlook: if the total fluorine content exceeds 50 mg/kg, manufacturers, importers and downstream users within the meaning of the REACH Regulation must, on request, prove to the manufacturer or importer of the packaging which share of the measured fluorine is attributable to PFAS and which to non-PFAS, so that the latter can draw up the technical documentation. This obligation is set out directly in Article 5(5)(c) and is a strong argument with suppliers who are reluctant.

Four clarifications from the Commission FAQ:

PFAS are defined by structure, not by a list. Any substance that contains at least one fully fluorinated methyl or methylene carbon atom without any hydrogen, chlorine, bromine or iodine atom attached to it is covered, with narrowly defined structural exceptions. A CAS list of the substances concerned is expressly not being published.

Intentionally added and unintentionally present PFAS are treated alike. The text of the Regulation makes no distinction. A supplier's statement that PFAS were not added therefore does not answer the question.

There is no harmonised test methodology yet. The Commission is working on it with the market surveillance authorities and the EU Reference Laboratory for food contact materials.

The rule is under review. By 12 August 2030 the Commission will assess whether paragraph 5 needs to be amended or repealed in order to avoid overlaps with PFAS restrictions under the Food Contact Materials Regulation, REACH or the POPs Regulation. Until then it applies unchanged.

The Commission's testing route

Because there is no harmonised method, the Commission recommends a three-step approach to the authorities in its guidance for enforcing the limit values. For companies this is the most important practical information on the whole topic, because step 1 is considerably cheaper than a full PFAS analysis.

Step 1: Determine the total fluorine content. If it is below 50 mg/kg, the sample can be considered compliant. The Commission expressly states that, according to the evidence available to it, all samples that pass step 1 also meet the requirements of steps 2 and 3.

Step 2: Distinguish organic fluorine. If the total fluorine content is above 50 mg/kg, methods such as pyrolysis GC/MS can be used to check whether the fluorine is organic (that is, PFAS) or inorganic. If the organic fluorine content is below 50 mg/kg, the sample can be considered compliant.

Step 3: Targeted analysis. To verify the values of 25 and 250 ppb, the Commission recommends a direct TOP assay, that is, the determination of the total oxidisable precursors.

For your own evidence this means: start with the total fluorine determination, for example by combustion ion chromatography. It is comparatively inexpensive, and a value below 50 mg/kg documents compliance with all three limit values. Only if this value is exceeded is it worth discussing organic fluorine and a TOP assay. Important: a value above 50 mg/kg is not yet non-compliance, only the point at which further testing is required.

The official controls of food contact materials under Regulation (EU) 2017/625 remain unaffected. The testing route does not replace them.

No sell-through of existing stocks

This is the sentence that silences advisory meetings: the Regulation provides no transitional period for selling through stocks of PFAS-containing packaging manufactured before 12 August 2026. Food-contact packaging placed on the market after that date must comply with the limit values. Packaging placed on the market before that date may remain on the market.

The difference therefore lies in placing on the market, not in production. A coated baking release film produced in July 2026 and first made available in October 2026 must comply. The same film already delivered to a customer in July may continue to be used.

Anyone who still has stocks with a fluorinated coating in the warehouse today should therefore clarify two things: when they were or will be placed on the market, and whether the total fluorine content is below 50 mg/kg. For baking papers, grease-resistant papers, pizza boxes, popcorn bags and fast-food packaging, fluorinated coatings were common for a long time; many suppliers have switched, but not all, and not everywhere at the same time.

How evidence is provided

Paragraph 6 requires evidence in the technical documentation under Annex VII. What has to go in is less than many fear.

There is no obligation to have a test report for each batch. Under Article 16, supplier declarations are also valid documents, regardless of whether the supplier is based in the EU. Whether a declaration is sufficient or a test report is needed is decided by your risk analysis, which Annex VII requires anyway.

A useful rule of thumb for the classification:

Low risk, a supplier declaration is usually sufficient. Unprinted corrugated board, uncoated papers, glass without recycled content, common plastics without a barrier layer and without food contact.

Medium risk, a declaration stating the basis of evidence, a test report on change. Packaging with multicolour printing, materials with recycled content, metal closures, coatings without food contact.

Elevated risk, a test report. Anything with food contact and a grease or moisture barrier, fluorinated coatings, recycled glass with conspicuous values, materials from supply chains without reliable data.

For each component, the documentation should contain the measured value with unit, the basis of evidence (test report or supplier declaration), the method or standard applied and the date. For heavy metals, CEN/CR 13695-1 is the usual reference; for total fluorine, combustion ion chromatography. Also record in writing why you chose which depth of evidence for which component; that is exactly the risk analysis.

For paragraph 1, the minimisation of substances of concern, a qualitative description is sufficient: supplier declarations on substances on the REACH Candidate List, the choice of printing inks, avoiding certain additives. No numerical value is required.

How this is embedded in the documentation and the declaration is explained in PPWR declaration of conformity: template and mandatory content under Annex VIII.

The most common mistakes

1. Testing only the substrate. The heavy metal limit applies to the unit including inks, varnishes and adhesives.
2. Looking at individual values instead of the sum. Four unremarkable values can together exceed 100 mg/kg.
3. Accepting "no PFAS added" as evidence. The limit values also apply to unintentionally present PFAS.
4. Starting with the most expensive analysis. Total fluorine determination is step 1 and is sufficient in most cases.
5. Treating a total fluorine value above 50 mg/kg as non-compliance. It only triggers further testing steps.
6. Hoping for a sell-through period. There is none.
7. Testing for PFAS even without food contact. Paragraph 5 applies only to food-contact packaging. The heavy metal limit, by contrast, applies to all packaging.
8. Not using the upstream suppliers' duty to provide information. Above 50 mg/kg total fluorine it arises directly from the Regulation.

How to proceed in practice

1. Mark the components with food contact. The PFAS limits apply only to these. This classification is the most important decision, because it halves or doubles the testing effort.

2. Classify the risk for each component. Using the logic above, with a written justification.

3. Request supplier data. Heavy metal sum with method and date, for food contact additionally total fluorine, and confirmation that the information also covers unintentionally present substances.

4. Have testing carried out where necessary. Total fluorine first, further testing only if the value is exceeded.

5. Clarify stocks. Which food-contact packaging was placed on the market before 12 August 2026, and which is still in the warehouse?

6. Document. Values, basis of evidence, method, date and the justification of the depth of testing, for each component.

7. Monitor changes. New supplier, new printing ink, new coating: test again. The technical documentation must be kept up to date.

How Polygon One helps

In the PPWR module, substance data is recorded per component, not per article, because the limit value depends on the unit including inks and adhesives. The field for the heavy metal sum gives immediate feedback on whether the value of 100 mg/kg is met. The food contact switch unlocks the PFAS fields, that is, individual value, sum and total fluorine, each with basis of evidence and measurement method; a total fluorine value below 50 mg/kg is recorded as evidence of compliance with all three limit values, whereas a higher value is never recorded as non-compliance but as a reason for further testing.

Every substance value needs a basis of evidence (test report or supplier declaration); otherwise the entry cannot be submitted. Both routes are valid under Article 16; a laboratory report as a file is not mandatory. The values then flow into the technical documentation under Annex VII and into the declaration of conformity.

Two limitations you should know about: Polygon One does not assess test reports and does not make risk decisions on your behalf. And the exemption for recycled glass is not yet mapped; any value above 100 mg/kg is flagged as an exceedance. If you use recycled glass, talk to us and we will solve it case by case.

If you would like to see how your substance data looks in this structure, book a demo or read on at the product page for the PPWR module.

Download the testing plan

Two pages for quality assurance and purchasing: risk classification by component type, the three-step testing route as a decision aid, wording templates for the supplier request including the duty to provide information above 50 mg/kg total fluorine, and a table for documenting the values.

• Download: PPWR substance evidence, testing plan for heavy metals and PFAS (PDF)

Frequently asked questions

Which PFAS limit values apply to food packaging?

25 ppb per individual substance in targeted analysis, 250 ppb as a sum and 50 ppm for total PFAS including polymeric PFAS. They have applied since 12 August 2026.

From when does the PFAS ban apply?

Since 12 August 2026, with no transitional period for stocks. What matters is the time of placing on the market, not production.

How do I prove that packaging is PFAS-free?

Via the Commission's three-step route. A total fluorine content below 50 mg/kg counts as evidence for all three limit values. Under Article 16, a supplier declaration is also sufficient as the basis of evidence.

Does the PFAS limit also apply without food contact?

No. Article 5(5) concerns only packaging that comes into contact with food. The heavy metal limit, by contrast, applies to all packaging.

Is there a list of the PFAS concerned?

No. The Commission expressly does not publish a CAS list. The structural definition in Article 5(5) is decisive.

What does the limit of 100 mg/kg apply to?

To the sum of lead, cadmium, mercury and hexavalent chromium, relating to the packaging or its components including printing inks, varnishes and adhesives.

Do I need a test report for every batch?

No. The Regulation does not require this. Whether a supplier declaration is sufficient is decided by your risk analysis under Annex VII.

What applies to recycled glass and reusable crates made from recycled material?

For recycled glass, the exemption under Decision 2001/171/EC continues to apply. For plastic crates and pallets in closed loops, the exemption under Decision 2009/292/EC continues to apply; in Germany, Sections 14 to 18 VerpackDG lay down the conditions, including a return rate of at least 90 per cent and a separate declaration of conformity.

Sources and status: Regulation (EU) 2025/40 (OJ L, 22 January 2025), Article 5 and Annex VII. Commission guidance C/2026/3702, section on Article 5. Commission FAQ on the PPWR, second edition (August 2026), section III, in particular questions 14 and 16 to 20. Packaging Law Implementation Act (VerpackDG), BGBl. 2026 I No 207, Sections 14 to 18. Commission Decisions 2001/171/EC and 2009/292/EC. This article describes the legal position as at September 2026 and does not replace legal advice.