Which substances are no longer permitted in packaging?

Heavy metals threshold and PFAS ban

Two categories of substances are explicitly restricted under the PPWR: heavy metals above a threshold value, and PFAS in packaging that comes into contact with food. For heavy metals, a threshold of 100 mg/kg applies — the sum of lead, cadmium, mercury and hexavalent chromium in the packaging. If packaging exceeds this level, it does not comply with the requirements of the regulation. For PFAS, a ban applies specifically to packaging intended for contact with food; outside this context, the PPWR does not regulate PFAS separately.

For anyone who has packaging produced or designs it themselves, this means that the composition of the material — not just the shape or weight — is part of the requirements being assessed. This affects both primary packaging (directly around the product) and secondary and tertiary packaging, with the key point being that food contact material follows a separate, stricter approach due to the PFAS ban. Where there is doubt whether a material, coating or ink used falls under one of these categories, the substantiation lies in the technical documentation and, where necessary, in laboratory tests from the supplier — something that also appears in the packaging file and the conformity declaration.

Where this appears in Article 5

These two requirements follow from Article 5 of Regulation (EU) 2025/40, which sets out the material requirements for packaging alongside the requirements for reusability and recyclability elsewhere in the regulation. Because it is a regulation, this threshold value and this ban apply directly and equally in every Member State, without any country being able to set its own, different standard for it. For the precise measurement methods, exemptions and any transition provisions for existing stocks, the text of Article 5 itself is the first source to consult.