The EU’s Packaging and Packaging Waste Regulation (PPWR) has brought a longstanding restriction on heavy metals into a much broader framework for packaging compliance.
Under Regulation (EU) 2025/40, the combined concentration of lead, cadmium, mercury and hexavalent chromium resulting from substances present in packaging or packaging components must not exceed 100 mg/kg, equivalent to 100 parts per million (ppm) by weight.
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The PPWR generally applies from 12 August 2026, bringing chemical composition alongside recyclability, recycled content, packaging reduction and other requirements governing packaging placed on the EU market.
The 100 mg/kg limit itself is not new. It was established under the EU’s previous Packaging and Packaging Waste Directive. What has changed is the regulatory context: the restriction now forms part of a directly applicable regulation with wider requirements covering packaging sustainability, circularity and substances of concern.
For manufacturers, converters, brands and importers, the issue is therefore not simply whether packaging meets a numerical threshold. Businesses also need reliable information about what their packaging contains and documentation capable of demonstrating conformity.
What the 100 mg/kg heavy metal limit means
Article 5 of the PPWR covers four heavy metals: lead, cadmium, mercury and hexavalent chromium.
Crucially, the regulation sets a combined limit. It does not allow each substance to reach 100 mg/kg independently. The sum of their concentrations resulting from substances present in packaging or packaging components must not exceed 100 mg/kg.
The requirement covers packaging components as well as packaging as a whole. Chemical compliance is therefore relevant across the packaging specification, rather than only to the main substrate.
Article 5 also places the heavy metal limit within a broader approach to substances of concern. Packaging must be manufactured so that the presence and concentration of such substances in packaging materials and components are minimised.
The regulation also considers what happens to these substances during waste management, including their potential presence in secondary raw materials and material destined for disposal.
Chemical composition can therefore remain relevant after a pack has completed its first use. Substances present in packaging can potentially move with materials into recycling and secondary raw-material streams.
The PPWR allows the European Commission to lower the 100 mg/kg limit through delegated acts to take account of scientific and technical progress. It can also amend the conditions applying to existing derogations.
Conformity assessment and technical documentation
The heavy metal limit also forms part of the PPWR’s wider conformity-assessment system.
Before placing packaging on the market, manufacturers must carry out, or have carried out, the required conformity assessment and draw up the technical documentation specified in Annex VII. Once conformity has been demonstrated, manufacturers must also draw up an EU declaration of conformity.
Manufacturers must take account of changes to packaging design or characteristics that could affect conformity. Where a change could have an impact, the packaging must be reassessed.
This increases the importance of reliable information from suppliers of substrates, inks, coatings, adhesives, closures and other components.
Brands sourcing finished packaging also need confidence that the information supporting conformity remains accurate when materials, formulations or suppliers change.
Why recycled packaging creates a compliance challenge
The EU’s 100 ppm packaging heavy metal limit has been in place for many years.
Directive 94/62/EC progressively reduced the permitted combined concentration of lead, cadmium, mercury and hexavalent chromium before establishing the 100 ppm ceiling that the PPWR retains.
Its continued presence in the new regulation highlights a challenge at the heart of circular packaging: increasing material circulation while controlling substances that may have entered recycling streams in the past.
This is particularly visible in glass packaging.
EU rules provide a derogation under specified conditions because recycled glass can contain heavy metals originating from historic material already circulating through the recycling system. The derogation can allow the limit to be exceeded where this results from recycled material rather than the intentional introduction of the regulated metals during manufacture.
A separate derogation covers certain plastic crates and pallets operating within closed and controlled product loops. Conditions apply to areas including recycling, material inputs, identification, return rates and record keeping. Intentional introduction of the four regulated heavy metals is not permitted.
The PPWR retains the framework for these established derogations and gives the Commission powers to amend their conditions. Future exemptions under the relevant provisions must be justified case by case and limited in time.
These exceptions illustrate why recycled content and chemical compliance cannot always be considered separately.
Material recovered from older products can contain legacy substances even when those substances are no longer intentionally used in new packaging. Increasing recycled content can therefore create a need for better knowledge of feedstock composition rather than reducing the importance of chemical controls.
The PPWR’s recitals support the principle that limits on hazardous substances should generally apply equally to virgin and recycled materials, while recognising that exceptional circumstances may justify specific derogations.
For packaging suppliers and users, this puts greater emphasis on traceability. Knowing that a pack contains recycled material may not, by itself, provide enough information to understand its chemical profile.
What packaging businesses need to check
Heavy metal compliance starts with understanding the complete packaging specification.
Businesses should consider whether their compliance records cover individual components and treatments rather than only the main packaging substrate.
Depending on the pack, relevant supplier information could extend to:
- Inks, coatings and adhesives
- Closures and other components
- Paper, board, plastic, glass and metal
- Recycled feedstocks and other secondary materials
Supplier and formulation changes also matter.
The PPWR requires manufacturers to have procedures in place so that series production remains in conformity. Changes to packaging design or characteristics must be taken into account, and packaging must be reassessed where a change could affect conformity.
This makes chemical compliance an ongoing supply-chain issue rather than a one-off check when a packaging format is first developed.
Documentation and other EU requirements
Technical documentation also has a longer-term role.
Under Article 15, manufacturers must retain the required technical documentation and EU declaration of conformity for five years after single-use packaging is placed on the market and 10 years in the case of reusable packaging.
Chemical compliance under the PPWR must also be considered alongside other EU legislation. Article 5 states that the heavy metal requirement applies without prejudice to restrictions under REACH and, where applicable, EU rules covering food-contact materials.
The heavy metal restriction is also part of a wider PPWR focus on packaging chemistry. From 12 August 2026, the regulation introduces restrictions on per- and polyfluoroalkyl substances (PFAS) in food-contact packaging, subject to specified concentration limits and other applicable EU legislation.
The regulation’s focus on packaging chemistry is also set to develop further. By 31 December 2026, the European Commission, assisted by the European Chemicals Agency, is required to prepare a report on substances of concern in packaging and packaging components.
The work will examine the extent to which such substances negatively affect reuse and recycling or have an impact on chemical safety.
Chemical compliance becomes part of circularity
For packaging businesses, the 100 mg/kg heavy metal limit is therefore both familiar and newly relevant.
The numerical threshold has been carried over from earlier EU legislation, but it now sits within a regulatory system placing greater emphasis on conformity assessment, technical documentation and knowledge of packaging composition.
As recycled materials become more important to packaging design, manufacturers, converters, brands and importers will increasingly need to understand not only whether a pack can enter the next material cycle, but what substances could travel with it.
Circularity does not remove the need for chemical control. It makes knowing what is in the packaging even more important.
