Guide to EU PPWR Substance Restrictions

The Packaging and Packaging Waste Regulation (PPWR) restricts substances in packaging materials, specifically heavy metals and PFAS. This guide provides an overview of the substance restrictions in Article 5 of the PPWR and how you can demonstrate compliance.

• PPWR restricts lead, cadmium, mercury and hexavalent chromium
• PPWR restricts PFAS in food-contact packaging
• Testing is generally required to verify the substance contents

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Overview

The following tables summarise substance restrictions mentioned in Article 5 of the PPWR:

*The sum of lead, cadmium, mercury and hexavalent cadmium concentrations should not exceed 100 mg/kg

**Polymeric PFAS excluded from quantification

***Additional documentation requirements are specified in Article 5(5c)

Notes

PPB refers to parts per billion

PPM refers to parts per million

Heavy metals

The PPWR mandates that the following heavy metals cannot exceed 100 mg/kg in packaging or packaging components:

• Lead
• Cadmium
• Mercury
• Hexavalent chromium

These restrictions are not new. The exact same list of heavy metals (and the 100 mg/kg limit) was established by the Packaging and Packaging Waste Directive, which will be replaced by the PPWR.

PFAS

Per- and polyfluorinated alkyl substances (PFAS) is restricted in food packaging materials and cannot contain these substances in amounts equal to or above the limits. These can be found in the table above.

Note that the specific limit depends on how the PFAS is measured in the packaging material.

Another area of interest is that PFAS is a group of substances. Rather than listing every possible substance that may count as a PFAS, the PPWR instead provides the following definition:

It can, in practice, be difficult for companies to determine if their packaging contains PFAS and which specific substances to test for. My best recommendation is to discuss this with your lab.

Testing Report

Article 5(6) of the Packaging and Packaging Waste Regulation (PPWR) requires that compliance with the heavy metals and PFAS restrictions must be provided in the technical documentation.

In practice, this means that you need to include test reports demonstrating that your packaging materials do not contain restricted heavy metals or PFAS above the set limits.

There are essentially two ways you can obtain test reports.

a. Obtain test reports from your supplier

This is the most cost effective option, as you may not need to arrange third-party testing. That said, you should not take for granted that packaging suppliers outside the EU can provide pre-existing test reports demonstrating compliance with the PPWR.

b. Arrange third-party testing

The other option is to send packaging samples to a company like QIMA or TUV Rheinland, which then carries out testing to verify if the materials contain heavy metals or PFAS above the limits.

Once completed, you will receive a test report that you can include in the technical documentation.

FAQ

Which heavy metals are restricted in packaging materials?

Article 5(4) of the Packaging and Packaging Waste Regulation (PPWR) sets restrictions for lead, cadmium, mercury, and hexavalent chromium.

Are PFAS restricted in packaging materials?

Yes, chemicals defined as PFAS are subject to restrictions in Article 5(4) of the Packaging and Packaging Waste Regulation (PPWR).

How can we ensure that packaging materials do not contain restricted substances?

You must either arrange third-party testing or obtain test reports from your material suppliers.

What can happen if the packaging contains restricted substances?

Packaging materials containing restricted substances above the set PPWR limits could potentially be subject to recalls.

Are packaging materials subject to other substance restrictions?

Yes, PPWR only restricts heavy metals and PFAS. Additional substance restrictions relevant to packaging materials can be found in the REACH and POPs regulations. Food packaging is also subject to various FCM regulations, which also set substance restrictions.