Yes, the European packaging regulation (PPWR) sets requirements for the substances that may be present in packaging material. For four heavy metals — lead, cadmium, mercury and hexavalent chromium — a maximum content limit has existed for some time, and that limit remains in force under the PPWR. What is new is that the regulation now contains, for the first time, a specific provision on PFAS, the group of persistent fluorinated substances, in packaging that comes into contact with food.
For most webshops that purchase standard cardboard boxes, film or plastic containers from an established supplier, this topic is not a daily concern. The responsibility for demonstrating that packaging complies with the standard rests primarily with the manufacturer of the packaging material itself. But anyone who has packaging made to their own design, has printing applied, or packages food products, should know where this rule comes from and when it becomes relevant.
Heavy metals: an established rule that remains in force
The restriction on lead, cadmium, mercury and hexavalent chromium has existed since the old European packaging directive and has been incorporated into the PPWR. It concerns a maximum content limit for the sum of these four substances in the packaging material, regardless of whether it is cardboard, plastic, glass, metal or wood. For standard packaging purchased through regular suppliers, this is usually already incorporated into the manufacturer's production standards. The problem is more likely to arise with recycled material, certain inks, coatings or metal closures, where residual concentrations may occur that are not necessarily within the limit.
PFAS: new for packaging that comes into contact with food
The PPWR contains a separate provision on PFAS in packaging intended to come into contact with food. These substances are used, among other things, to give fat- and water-repellent properties to paper and cardboard, for example in fast food packaging, baking paper or pizza boxes. The precise limit values and the date on which this provision becomes applicable are described in the regulation itself; those dealing with this should consult the current text on EUR-Lex rather than relying on summaries. For packaging that does not come into contact with food — the majority of what an average webshop ships — this specific PFAS provision does not apply.
Who must demonstrate this?
The responsibility for demonstrating substance contents rests primarily with the person who manufactures or has the packaging manufactured, not with the party that only uses the packaging to ship products. For a webshop that purchases cardboard boxes from a supplier, this means in practice that the supplier must be able to support compliance with these substance limits, for example via a declaration or test report. Anyone who designs their own packaging, has it produced under their own brand, or acts as a filler in the sense of the regulation, is more likely to be in a position where this substantiation is part of their own technical file. Whether that applies to your situation also depends on your role as a manufacturer, filler or importer; see in a few questions which role applies to your packaging provides initial guidance.
What this practically means for your procurement
The most concrete thing you can do is ask your packaging supplier whether the material complies with the applicable limit values for heavy metals and, for food contact packaging, with the PFAS provision. Established suppliers typically have this information available, often as part of their own quality documentation. For packaging with printing, coating or special finishing, it is advisable to ask about this explicitly, because these processes are sometimes the source of elevated substance levels. This is not a risk assessment or estimate, but a practical question you can ask as a buyer before you put a packaging into use.
Where this appears in your dossier
The substantiation of substance levels belongs in the technical dossier for your packaging, alongside the other elements that the conformity declaration according to Annex VIII requires. You can read more about what exactly belongs there and how it is structured in the knowledge bank per packaging subject. How we compile the information on these subjects and where it comes from is explained on the page on our working method.
Are you uncertain whether this subject is relevant for your packaging, or would you first like to know what role you have under the regulation before you look further into substance levels and dossiers? The free role finder provides a first indication for this, and the frequently asked questions address a number of situations that often come up alongside this subject.