PPWR Article 5: Substances in Packaging
Top line summary
Substances of concern must be minimized in packaging. Heavy metals limits maintained (sum ≤ 100 mg/kg). PFAS restricted in food-contact packaging from 12 August 2026 with specific concentration limits.
Summary
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📅 Key Dates
Date | Event | Priority |
11 Feb 2025 | PPWR enters into force | 🔴 Critical |
31 Dec 2025 | Member States inform Commission + ECHA on substances affecting re-use/recycling | 🔵 Info |
12 Aug 2026 | Article 5 applies – PFAS + heavy metals limits mandatory | 🔴 Critical |
31 Dec 2026 | Commission (+ ECHA) prepares substances of concern report | 🔵 Info |
12 Aug 2030 | Commission reviews PFAS restriction (amend/repeal assessment) | 🟠 Watchlist |
Color Guide: 🔴 Critical deadline | 🟠 Important milestone | 🔵 Information/Review
⚠️ Environmental Omnibus Update (December 2025)
🔵 GUIDANCE COMING SOON – Commission Notice and FAQ expected early 2026
On 10 December 2025, the European Commission published the Environmental Omnibus package (COM(2025) 980).
Relevant to Article 5: PFAS Testing Guidance
Omnibus Commitment | Status | Expected |
Commission Notice and FAQ on PFAS testing requirements | 🔵 Announced | Early 2026 |
Guidance on application dates | 🔵 Announced | Early 2026 |
Guidance on labelling requirements | 🔵 Announced | Early 2026 |
Guidance on reuse targets | 🔵 Announced | Early 2026 |
What This Means for Article 5 Compliance
Topic | Current Situation | Omnibus Impact |
PFAS Testing Methods | Article 5(5) sets limits but testing methodology details unclear | Commission guidance will clarify testing protocols |
Targeted vs. Total PFAS | Industry uncertainty on which compounds to test | FAQ expected to provide clarity |
12 Aug 2026 Deadline | Mandatory compliance date | UNCHANGED – deadline remains in force |
Heavy Metals Limits | 100 mg/kg sum limit | UNCHANGED – no amendments proposed |
Substances of Concern | Minimization requirement | UNCHANGED – no amendments proposed |
⚠️ Critical Notes
- The Omnibus introduces guidance only for Article 5 – no amendments to the legal text
- All Article 5 requirements and deadlines remain in force as written
- PFAS testing guidance will help with practical compliance but does not change thresholds
- Monitor Commission publications for the Notice and FAQ in early 2026
Article 5 – Requirements Overview
General Principle (Article 5(1))
🔴 MANDATORY from 12 Aug 2026
Substances of concern as constituents of packaging material or packaging components shall be minimized.
Minimization scope includes:
Aspect | Description |
Presence | Minimize substances in packaging and components |
Concentration | Reduce concentration levels |
Emissions | Limit emissions during production |
Waste outputs | Minimize presence in secondary raw materials, ashes |
Microplastics | Address adverse environmental impacts |
Compliance: Demonstrated in Annex VII technical documentation.
🧪 Heavy Metals Restriction (Article 5(4))
🔴 MANDATORY LIMIT from 12 Aug 2026
Restricted Heavy Metals
Metal | Symbol |
Lead | Pb |
Cadmium | Cd |
Mercury | Hg |
Hexavalent Chromium | Cr(VI) |
Concentration Limit
Requirement | Limit |
Sum of all four metals | ≤ 100 mg/kg in packaging or packaging components |
Compliance: Demonstrated in Annex VII technical documentation.
Commission Powers (Article 5(4))
Commission may adopt delegated acts to:
Power | Description |
Lower limits | Reduce concentration limits for any of these metals |
Exemption conditions | Determine conditions where sum limit does not apply to: |
• Recycled materials | |
• Product loops in closed and controlled chains | |
• Certain packaging types or formats |
Principle: Same concentrations should apply to virgin and recycled material (exceptional derogations on case-by-case basis).
🍽️ PFAS Restriction in Food-Contact Packaging (Article 5(5))
🔴 MANDATORY PROHIBITION from 12 Aug 2026
Scope: Food-contact packaging shall not be placed on the market if PFAS concentration equals or exceeds limits below (unless already prohibited under other EU law).
PFAS Concentration Limits
Test Method | Limit | What’s Measured |
Targeted PFAS analysis | ≥ 25 ppb | Any individual PFAS (polymeric PFAS excluded from quantification) |
Sum of targeted PFAS | ≥ 250 ppb | Sum of PFAS with prior degradation of precursors where applicable (polymeric PFAS excluded) |
Total PFAS | ≥ 50 ppm | Including polymeric PFAS |
Additional Fluorine Documentation Requirement
Condition | Obligation |
If total fluorine > 50 mg/kg | Manufacturer/importer/downstream user must provide technical documentation (Annex VII) demonstrating whether fluorine is from PFAS or non-PFAS sources |
PFAS Definition (Article 5(5))
“PFAS” means: Any substance containing at least one fully fluorinated methyl (CF₃-) or methylene (-CF₂-) carbon atom (without H/Cl/Br/I attached).
Exceptions: Substances only containing:
- CF₃-X or X-CF₂-X′
- Where X = -OR or -NRR′
- Where X′ = methyl (-CH₃), methylene (-CH₂-), aromatic group, carbonyl group (-C(O)-), -OR′′, -SR′′ or -NR′′R′′′
- Where R/R′/R′′/R′′′ = hydrogen (-H), methyl (-CH₃), methylene (-CH₂-), aromatic group or carbonyl group (-C(O)-)
Compliance: Demonstrated in Annex VII technical documentation.
PFAS Review
Deadline | Action |
By 12 Aug 2030 | Commission evaluates need to amend or repeal PFAS restriction to avoid overlaps with other EU restrictions (including REACH universal PFAS restriction) |
🇪🇺 Member State Restriction Pathway (Article 5(2-3))
Reporting Obligation (Article 5(2))
🔵 DEADLINE: 31 Dec 2025
If Member State considers a substance negatively affects re-use/recycling:
Action | Requirement |
Notify | Inform Commission + ECHA by 31 Dec 2025 |
Provide data | Submit relevant risk assessments or other data (where available) |
Request for Restrictions (Article 5(3))
Member States may request Commission to consider restricting substances of concern that negatively affect re-use/recycling for reasons other than chemical safety.
Request Element | Description |
Report | Document substance identity and uses |
Description | How substance hinders recycling (non-chemical safety reasons) |
📊 Commission Assessment (Article 5(6))
🔵 DEADLINE: 31 Dec 2026
By 31 Dec 2026: Commission (assisted by ECHA) prepares report on substances of concern in packaging/components.
Report Scope
Coverage | Details |
Re-use/recycling impact | Extent to which substances negatively affect re-use/recycling |
Risk assessment | Extent to which substances present unacceptable risk to human health/environment |
Report May Include
Element | Description |
Substances list | Substances of concern present in packaging/components |
Risk indicators | Unacceptable risk indicators |
Follow-up Actions
Commission considers appropriate measures, including:
- Legislative proposal for restrictions (per Article 6(4)(a))
- Other follow-up actions
📋 Compliance Summary Table
Requirement | Applies From | Limit/Obligation | Evidence Required |
Substances of concern | 12 Aug 2026 | Minimized (presence, concentration, emissions, waste outputs, microplastics) | Annex VII |
Heavy metals (sum) | 12 Aug 2026 | ≤ 100 mg/kg (Pb + Cd + Hg + Cr(VI)) | Annex VII |
PFAS (any individual) | 12 Aug 2026 | < 25 ppb (targeted analysis, polymeric excluded) | Annex VII |
PFAS (sum) | 12 Aug 2026 | < 250 ppb (sum targeted, polymeric excluded) | Annex VII |
PFAS (total) | 12 Aug 2026 | < 50 ppm (including polymeric) | Annex VII |
Total fluorine | 12 Aug 2026 | If > 50 mg/kg, document source (PFAS vs. non-PFAS) | Annex VII |
✓ Development Team Checklist
Immediate Actions
- Review material composition for substances of concern
- Verify heavy metals sum ≤ 100 mg/kg (Pb, Cd, Hg, Cr(VI))
- Test food-contact packaging for PFAS compliance:
- Individual PFAS < 25 ppb (targeted analysis)
- Sum of PFAS < 250 ppb (targeted analysis)
- Total PFAS < 50 ppm (including polymeric)
- If total fluorine > 50 mg/kg, prepare documentation on fluorine source
Documentation
- Prepare Annex VII technical documentation for all substance requirements
- Maintain test reports and compliance certificates
- Document minimization efforts for substances of concern
Timeline Actions
- Ensure compliance by 12 Aug 2026 (critical deadline)
- Monitor Commission PFAS testing guidance (expected early 2026)
- Monitor Commission PFAS restriction review (by Aug 2030) for potential changes
✓ Regulatory Team Checklist
Monitoring
- Track Member State submissions to Commission/ECHA (31 Dec 2025)
- Monitor Commission Notice and FAQ on PFAS testing (expected early 2026)
- Monitor Commission substances of concern report (31 Dec 2026)
- Follow Commission PFAS restriction review (by Aug 2030)
- Watch for delegated acts on heavy metals limits or exemptions
Verification
- Confirm testing methodologies for PFAS (targeted vs. total)
- Verify heavy metals testing procedures
- Ensure Annex VII documentation completeness
- Check for overlaps with other EU substance restrictions (REACH, POPs)
Strategic Planning
- Identify substances that may hinder recycling/re-use
- Assess potential future restrictions based on Commission report
- Coordinate with suppliers on substance-level compliance
- Plan for potential PFAS restriction amendments post-2030
- Prepare for REACH universal PFAS restriction (timeline TBD)
🔗 Legal References
- Primary Regulation
- Regulation (EU) 2025/40 – Article 5
- December 2025 Omnibus Package, COM(2025) 980 – “Simplifying for Sustainable Competitiveness” 📄 Environment DG Publication
- Related PPWR Articles
- Referenced EU Law
Legislation | Relevance |
Regulation (EC) No 1935/2004 | Food-contact materials |
Regulation (EC) No 1907/2006 | REACH (chemicals regulation, universal PFAS restriction pending) |
Regulation (EU) 2019/1021 | Persistent organic pollutants (POPs) |
Directive 94/62/EC | Previous Packaging Directive (repealed by PPWR) |
Commission Decisions (Maintained)
Decision | Scope |
Decision 2001/171/EC | Glass packaging derogation (heavy metals) |
Decision 2009/292/EC | Plastic crates/pallets derogation (heavy metals) |
Legal text - Law EU 40/2025
Check here the legal text
Article 5
Requirements for substances in packaging
- Packaging placed on the market shall be so manufactured that the presence and concentration of substances of concern as constituents of the packaging material or of any of the packaging components is minimized, including with regard to their presence in emissions and any outcomes of waste management, such as secondary raw materials, ashes or other material for final disposal, and to the adverse impact on the environment due to microplastics.
- The Commission shall monitor the presence of substances of concern in packaging and packaging components and shall take, where appropriate, the relevant follow-up measures.
By 31 December 2026, the Commission, assisted by the European Chemicals Agency, shall prepare a report on the presence of substances of concern in packaging and packaging components, to determine the extent to which they negatively affect the re-use and recycling of materials or impact chemical safety. That report may list the substances of concern present in packaging and packaging components and indicate the extent to which they could present an unacceptable risk to human health and the environment.
The Commission shall submit the report to the European Parliament, to the Council and to the committee referred to in Article 65 of this Regulation setting out its findings and shall consider appropriate follow-up measures, including:
(a) for substances of concern in packaging materials which primarily affect human health or the environment, the use of the procedures referred to in Article 68(1) and (2) of Regulation (EC) No 1907/2006 to adopt new restrictions;
(b) for substances of concern that negatively affect the re-use and recycling of materials in the packaging in which they are present, the establishment of restrictions as a part of design for recycling criteria in accordance with Article 6(4) of this Regulation.
If a Member State considers that a substance negatively affects the re-use and recycling of materials in the packaging in which it is present, it shall, by 31 December 2025, supply such information to the Commission and the European Chemicals Agency and, where available, refer to the relevant risk assessments or other relevant data.
- Member States may request the Commission to consider restricting, pursuant to Article 6(4), point (a), the use of substances of concern that potentially negatively affect the re-use and recycling of materials in packaging in which they are present, for reasons other than those related primarily to the chemical safety of those substances. Member States shall accompany such requests with a report documenting the identity and uses of the substances and a description of how the use of the substances in packaging hinders recycling, for reasons other than those related primarily to chemical safety. The Commission shall evaluate the request and present the results of that evaluation to the committee referred to in Article 65.
- Without prejudice to the restrictions on chemicals set out in Annex XVII to Regulation (EC) No 1907/2006 or, where applicable, to the restrictions and specific measures on food-contact materials and articles in Regulation (EC) No 1935/2004, the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium resulting from substances present in packaging or packaging components shall not exceed 100 mg/kg.
- From 12 August 2026, food-contact packaging shall not be placed on the market if it contains per- and polyfluorinated alkyl substances (PFAS) in a concentration equal to or above the following limit values to the extent that the placing on the market of packaging containing such a concentration of PFAS is not prohibited pursuant to another Union legal act:
(a) 25 ppb for any PFAS as measured with targeted PFAS analysis (polymeric PFAS excluded from quantification);
(b) 250 ppb for the sum of PFAS measured as the sum of targeted PFAS
(c) 50 ppm for PFASs (including polymeric PFAS); if total fluorine exceeds 50 mg/kg the manufacturer, importer or downstream user as defined respectively in Article 3, points (9), (11) and (13) of Regulation (EC) No 1907/2006 shall, upon request, provide to the manufacturer or the importer as defined respectively in Article 3(1), points (13) and (17), of this Regulation proof of the quantity of fluorine measured as content of either PFAS or non-PFAS in order for them to draw up the technical documentation as referred to in Annex VII to this Regulation.
‘PFAS’ means any substance that contains at least one fully fluorinated methyl (CF3-) or methylene (-CF2-) carbon atom (without any H/Cl/Br/I attached to it), except substances that only contain the following structural elements: CF3-X or X-CF2-X′, where X = -OR or -NRR′ and X′ = methyl (-CH3), methylene (-CH2-), an aromatic group, a carbonyl group (-C (O)-), -OR′′, -SR′′ or –NR′′R′′′; and where R/R′/R′′/R′′′ is a hydrogen (-H), methyl (-CH3), methylene (-CH2-), an aromatic group or a carbonyl group (-C(O)-).
By 12 August 2030, the Commission shall carry out an evaluation to assess the need to amend or repeal this paragraph in order to avoid overlaps with restrictions or prohibitions on the use of PFAS laid down in accordance with Regulations (EC) No 1935/2004, (EC) No 1907/2006, or (EU) 2019/1021.
- Compliance with the requirements set out in paragraphs 4 and 5 of this Article shall be demonstrated in the technical documentation drawn up in accordance with Annex VII.
- In order to take account of scientific and technical progress, the Commission may adopt delegated acts in accordance with Article 64 to amend this Regulation in order to lower the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium resulting from substances present in packaging or packaging components referred to in paragraph 4 of this Article.
- In order to take account of scientific and technical progress, the Commission may adopt delegated acts in accordance with Article 64 to supplement this Regulation in order to determine the conditions under which the sum of the concentrations referred to in paragraph 4 of this Article shall not apply to recycled materials or to product loops which are in a closed and controlled chain, as well as to determine the packaging types or formats of packaging, based on the packaging categories listed in Table 1 of Annex II to this Regulation, which shall be exempted from the requirements laid down in that paragraph. Such delegated acts shall be justified on the basis of a case by case analysis, time-limited, provide for appropriate marking and information requirements, and contain requirements for regular reporting in order to ensure that the exemption is regularly reviewed. Delegated acts adopted in accordance with this paragraph shall only be adopted to amend derogations established in Decisions 2001/171/EC and 2009/292/EC.
- By 12 August 2033, the Commission shall carry out an evaluation to assess whether this Article and the design for recycling criteria set out in accordance with Article 6(4) have contributed sufficiently to minimising the presence and concentration of substances of concern as constituents of packaging materials.
Source: Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, OJ L, 2025/40, 22.1.2025
