Since 12 August 2026, PPWR Article 5 has set two chemical limits for packaging. Packaging that touches food must stay under three PFAS limits, and all packaging must keep four heavy metals under 100 mg/kg.
The heavy metal limit is an old rule, but the PFAS limits are new, so food packaging is where most of the work is. Below is what each limit means, which parts of a pack it covers and how you show you meet it.
There is no grace period for old stock. Food packaging first sold in the EU after 12 August 2026 must meet the PFAS limits, even if it was made earlier.
What does PPWR Article 5 require?
Article 5 of Regulation (EU) 2025/40 is the part of PPWR that deals with chemicals in packaging. It has three rules, all in force since 12 August 2026, and the table below shows what each one asks of you.
| Rule | What it asks of you |
|---|---|
| Keep harmful substances low (Article 5(1)) | Make packaging with as few harmful substances as possible, also in recycled material and in what is left when the packaging becomes waste |
| Heavy metal limit (Article 5(4)) | Lead, cadmium, mercury and hexavalent chromium together may make up at most 100 mg per kg, in all packaging |
| PFAS limits (Article 5(5)) | Packaging that touches food must stay under three PFAS limits |
Only the heavy metal limit and the PFAS limits come with numbers you can test against. Article 5(6) says the proof for both must be kept in the pack's evidence file, called the technical documentation.
The first rule has no number attached. It is a general instruction to keep harmful substances out, and a Commission report due by the end of 2026 may turn parts of it into new limits.
Article 5 is the first of the packaging rules in Articles 5 to 12, which the guide to the PPWR requirements maps in full.
Which PFAS limits apply to food-contact packaging under PPWR?
PFAS are a family of thousands of man-made chemicals that keep grease and water out. That is why they have been used in paper food wrappers, pizza boxes and coated cartons.
They break down extremely slowly, and PPWR calls it an unacceptable health risk for people to take them in through food packaging.
Below are the three PFAS limits from Article 5(5). Packaging that touches food may not be sold if it reaches any of them.
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25 ppb for any single PFAS. ppb means parts per billion, the same as 25 micrograms in a kilo of packaging. The lab looks for specific, named PFAS, and the large plastic-like PFAS (polymers) are not counted here.
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250 ppb for the named PFAS added together. Where needed, the lab first turns related chemicals that can become PFAS into PFAS, so they are counted too. Polymers are again not counted.
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50 ppm for all PFAS of every kind, polymers included. ppm means parts per million, the same as 50 milligrams in a kilo. This limit catches what the other two leave out.
The third limit comes with a duty for chemical suppliers. If a material holds more than 50 mg of fluorine per kilo, the supplier must, when asked, show how much of that fluorine comes from PFAS. The packaging maker needs that answer for its evidence file.
PPWR defines PFAS by their chemical make-up, not by a list of names. Any substance with at least one fully fluorinated carbon atom counts, apart from a few listed exceptions, so the limits cover the whole family.
Does the PFAS ban cover every part of a food pack?
No. The PFAS limits only cover packaging that touches food. The European Commission defines that as packaging meant to touch food, or packaging that already touches food and was meant to.
When Denmark's environmental protection agency asked how that works on a real pack, the Commission confirmed the split below.
Below is how the rule splits across a typical food pack.
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Covered. Everything that touches the food, such as the bag inside a cereal box, a burger wrapper or a coated paper cup, including the inks, glues and coatings on those parts.
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Not covered. Outer parts that never touch the food, such as the carton around individually wrapped bars.
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No way out. Packaging made from recycled material must meet the limits too, and it does not matter whether the PFAS got there on purpose or by accident.
The heavy metal limit works differently, because it applies to every part of every pack. So the outer carton is outside the PFAS limits but still has to stay under 100 mg/kg of heavy metals.
How do you show your packaging is under the PFAS limits?
PPWR does not tell you to test. It tells you not to sell food packaging over the limits, and to show in your evidence file how you made sure of that.
There is no official EU test method for PFAS in food packaging yet. In its PPWR guidance document from the European Commission of 5 June 2026, the Commission recommends that inspectors check in three steps, and companies can use the same order.
Below are the three steps, cheapest first.
| Step | What the lab measures | Passes when |
|---|---|---|
| 1. All fluorine | All the fluorine in the sample | Under 50 mg per kg |
| 2. PFAS or not | Whether that fluorine comes from PFAS or from other sources, for example by heating the sample and identifying what it breaks into (pyrolysis-GC/MS) | PFAS fluorine under 50 mg per kg |
| 3. The two lower limits | Single PFAS and their total, with a test that also uncovers chemicals that turn into PFAS (a TOP test) | Under 25 ppb and 250 ppb |
The Commission adds that, on the evidence it has seen, every sample that passed step 1 also passed steps 2 and 3. A sample under 50 mg/kg at step 1 can therefore be treated as compliant.
In practice, that leaves each company to judge its own risk and test where PFAS are likely. Recycled paper of unknown origin, or a factory that also uses PFAS for other products, are good reasons to test.
What is the heavy metal limit in PPWR Article 5?
Article 5(4) limits lead, cadmium, mercury and hexavalent chromium to 100 mg per kg of packaging, counted together. It covers every packaging part, whatever it is made of and whatever it holds.
This is not a new rule. PPWR copies the limit from Article 11(1) of the old Packaging Directive 94/62/EC, and it comes on top of the EU's general chemical rules (REACH) and its rules for materials that touch food.
Below are the two exceptions that carry over from the old directive.
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Glass packaging. Decision 2001/171/EC lets glass packaging go over the limit under set conditions.
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Plastic crates and pallets. Decision 2009/292/EC does the same for plastic crates and plastic pallets.
Both exceptions stay until the Commission replaces them with a new rule. The Commission can also lower the 100 mg/kg limit later.
Who carries the Article 5 duties in the supply chain?
The manufacturer is responsible for Article 5. Everyone further down the chain has to check that work or avoid undoing it.
Below are the four roles and what each one owes under Article 5.
| Role | What it owes under Article 5 |
|---|---|
| Manufacturer | Only sells packaging that meets Article 5, checks this itself with no outside inspector, and keeps the proof for 5 years, or 10 for reusable packaging |
| Importer | Only brings in packaging from outside the EU after checking that the manufacturer did the check and has the evidence file |
| Distributor | Does not sell packaging it has reason to think breaks the limits, and stores and transports it so it stays within them |
| Fulfilment service provider | Stores, packs and ships packaging without putting its compliance at risk |
Much of the PFAS and heavy metal evidence has to come from material suppliers, and the guide on requesting packaging data from suppliers covers how to ask for it.
Can food packaging made before 12 August 2026 still be sold?
According to the Commission's guidance, food packaging that was already sold or handed on before 12 August 2026 can stay on the market and does not need to be recalled. What matters is the exact moment packaging counts as "placed on the market".
For food packaging sold to shoppers, multipacks included, that moment is usually when it is filled, because sealing can affect whether the pack meets the limits. So printed food bags bought empty in July 2026 and filled in September 2026 must meet the PFAS limits.
Transport packaging and packaging filled at the counter, such as takeaway cups, count from the moment the empty packaging is supplied. For packaging brought in from outside the EU, the moment is when it clears customs.
The figure below shows seven examples, not a full list. Anything that touches food falls under the PFAS limits, recycled trays and bags filled after 12 August 2026 included, while outer cartons, shipping boxes and cardboard sleeves around cans only face the heavy metal limit.
What does your declaration of conformity confirm about Article 5?
Every EU declaration of conformity states that the packaging meets Articles 5 to 12. For food packaging, that means a signed statement that it is under all three PFAS limits and the heavy metal limit.
The proof behind that statement goes in the technical documentation, the evidence file that lists what each part is made of, the methods used and any test reports.
If national inspectors doubt a declaration, that file is the first thing they ask for. The guide to the EU declaration of conformity explains the declaration itself, field by field.
Repax Declare builds the declaration for each packaging type, with all 8 Annex VIII fields and the signature block, a QR code to the live declaration and a new version whenever the pack changes.
Try Repax Declare for free - no card required Fill in the form, sign it, and get your first declaration. Try it freeDeclare does not test packaging or make it compliant. Keeping it under the PFAS and heavy metal limits stays the manufacturer's job under Article 15. Declare makes sure the declaration is correct, traceable and ready when an inspector asks.
Which parts of Article 5 are still being decided?
The limits above are fixed in law, but the European Commission still has follow-up work to do. As of October 2026, none of it has changed the rules that apply today.
Below are the four open points with their legal deadlines.
| Open point | What it could change | Legal deadline |
|---|---|---|
| Report on harmful substances in packaging | Could lead to new limits under the EU's chemical rules or its recycling rules | 31 December 2026 |
| Digital marking of harmful substances | A standard way to show each harmful substance and its amount in a digital code | 1 January 2030 |
| PFAS overlap check | Could change or remove the PFAS limits if other EU laws already cover them | 12 August 2030 |
| Review of Article 5 | Whether the article has cut harmful substances enough | 12 August 2033 |
New acts on packaging appear on the European Commission's packaging waste page, and the article text itself is in Regulation (EU) 2025/40 on EUR-Lex.
Frequently asked questions about PPWR Article 5
Below are the six questions packaging companies ask most often about the PFAS and heavy metal rules.
When does PPWR Article 5 start to apply?
Since 12 August 2026, the day PPWR started to apply across the EU. The PFAS limits for food packaging and the 100 mg/kg heavy metal limit both started that day, with no grace period for food packaging already in stock.
Do the PFAS limits apply to packaging that does not touch food?
No. The PFAS limits only cover packaging that touches food. Packaging for other products, and the outer parts of a food pack, still have to meet the heavy metal limit in Article 5(4).
Do I have to test every batch for PFAS?
No. PPWR sets limits, not a testing schedule. You judge how likely PFAS are in your materials, test where needed, and record your reasoning and any test reports in your evidence file.
Is recycled packaging exempt from the PFAS limits?
No. The European Commission's guidance says packaging made with recycled material gets no exception. If you use recycled material of unknown origin, that is a good reason to test it for PFAS.
What happens if packaging breaks the Article 5 limits?
National inspectors will tell the company to fix it, and if it does not, they can ban the packaging, take it off the market or recall it. Each EU country also sets its own penalties, due by 12 February 2027.
Is the heavy metal limit in PPWR new?
No. The 100 mg/kg limit on lead, cadmium, mercury and hexavalent chromium comes from the old Packaging Directive 94/62/EC. The exceptions for glass packaging and for plastic crates and pallets carry over too, until the Commission replaces them.
