Substances of concern in packaging: What Article 5 of the PPWR will regulate as of 12 August 2026
The PPWR sets limits on certain harmful substances in packaging – from heavy metals to PFAS. We explain what the rules are and where Klingele stands today.
An overview of the three groups of substances
Heavy metals
- Lead, mercury, cadmium, hexavalent chromium
- Total limit: 100 mg/kg (ppm)
- Applies to all packaging (regardless of material)
- Anchor link: Details on heavy metals
What applies:
- The sum of the concentrations of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg.
- This requirement applies to all packaging, regardless of the material.
- Applicable as of 12 August 2026.
Compliance with Klingele: Klingele corrugated cardboard packaging complies with the total limit of 100 mg/kg for heavy metals, as verified by ISEGA test report 15174-29.
PFAS
- ‘Forever chemicals’
- Limit values apply to food contact packaging
- (Anchor link: Details on PFAS)
What applies:
As of 12 August 2026, packaging intended to come into contact with food may not be placed on the market if it contains PFAS in concentrations equal to or exceeding the following limit values (in accordance with Article 5(5) of the PPWR).
| Limit value | What exactly does this apply to? | Note |
|---|---|---|
| 25 ppb (=25 μg/kg) | For each individual PFAS measured as part of a targeted analysis | Polymeric PFAS are not determined in this context |
| 250 ppb (=250 μg/kg) | For the total of PFAS measured by targeted analysis (including, where applicable, prior degradation of precursor compounds) | Polymeric PFAS are not determined in this context |
| 50 ppm (=50 mg/kg) | For total PFAS (including polymeric PFAS) | Applies as a threshold within the framework of the overall approach |
Important additional threshold: Total Fluorine (TF)
- If the total fluorine (TF) content is >50 mg/kg, the regulatory text stipulates that it must be established whether the fluorine is PFAS-derived or non-PFAS-derived, so that the technical documentation can be drawn up.
Note for clarity (optional as a small footnote):
- ppb = ‘parts per billion’ (here: μg/kg), ppm = ‘parts per million’ (here: mg/kg).
- The limit values apply to food contact packaging.
Other hazardous substances
- E.g. certain plasticisers, flame retardants
- Restriction if classified as hazardous
What applies:
- Furthermore, packaging must not contain certain plasticisers or flame retardants if these are classified as hazardous.
- For Klingele corrugated cardboard packaging, these groups of substances are generally not relevant to its use – in the case of special finishes (e.g. coatings), we assess this on a case-by-case basis.
FAQ – Frequently Asked Questions about Substances of Concern
No, the key factor is food contact.
No phase-out period is provided for food contact packaging placed on the market after 12 August 2026.
There is no harmonised EU method. A two-stage approach is therefore recommended: first, a risk-based assessment is carried out to determine how likely it is that PFAS are present in a material (e.g. depending on the raw material and process). Only where a risk is identified is a step-by-step analytical test carried out – starting with a simple screening for total fluorine content.
Yes, the limit values apply to the entire packaging unit, including any associated components.
Under the PPWR framework, the producer is responsible for establishing compliance (depending on the circumstances).
Yes, it applies to all packaging, regardless of the material used. Klingele corrugated cardboard packaging has been proven to comply with the limit of 100 mg/kg (ISEGA test report 15174-29).
Let’s go through the material requirements for your packaging together.
We’d be happy to advise you.
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