Article 5 carries forward and strengthens long-standing limits on hazardous substances in packaging, and adds a headline restriction on PFAS — the "forever chemicals" used for grease and water resistance.
Heavy metals
The sum of concentration levels of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg. This limit is inherited from the previous Directive and remains in force.
The PFAS restriction
The PPWR restricts per- and polyfluoroalkyl substances in food-contact packaging above defined thresholds, with the restriction applying from 18 months after entry into force. This directly affects grease-proof papers, moulded-fibre tableware, and some coated boards.
SVHCs and the wider chemical picture
Substances of very high concern under REACH still apply, and the regulation pushes toward minimising hazardous substances that hinder reuse or recycling. Your technical file should document that substances of concern are below the relevant thresholds.
What to do
- Audit food-contact items for intentionally-added PFAS, especially fibre-based formats.
- Collect test reports and supplier declarations for heavy metals and PFAS.
- Store the evidence against each packaging type so it is one click from the Declaration of Conformity.
PFAS thresholds and exemptions are detailed in the regulation and related acts. Verify the exact limits for your packaging type.