PPWR Article 5 Explained: Heavy Metals, PFAS and Total Fluorine in Plastic Packaging

Article 5 of Regulation (EU) 2025/40 addresses substances present in packaging and has immediate relevance for companies supplying or purchasing plastic packaging in Europe.

Two topics deserve particular attention:

Heavy metals

and

PFAS in food-contact packaging

Heavy Metals: The 100 mg/kg Limit

Under Article 5, the sum of:

• lead;

• cadmium;

• mercury;

• hexavalent chromium

resulting from substances present in packaging or packaging components must not exceed 100 mg/kg.

For plastic packaging buyers, this requirement can apply not only to the main container body but also to relevant packaging components.

That means a compliance review may need to consider:

body + lid + handle + inner stopper + liner + other packaging components.

PFAS Limits for Food-Contact Packaging

From 12 August 2026, food-contact packaging cannot be placed on the EU market when PFAS concentrations reach or exceed the limits specified in Article 5.

The regulation establishes three measurement thresholds:

25 ppb
for any individual PFAS measured through targeted analysis;

250 ppb
for the sum of PFAS under the defined targeted approach;

50 ppm
for PFAS including polymeric PFAS.

These thresholds make PFAS evaluation a significant issue for food-contact packaging compliance.

Why Is Total Fluorine Tested?

Total Fluorine, or TF, is often misunderstood.

A total fluorine result does not automatically mean that the fluorine present is PFAS.

Instead, the European Commission's 2026 guidance describes a stepwise enforcement approach.

As an initial screening step, where total fluorine is below 50 mg/kg, the sample may be considered compliant under the recommended approach. When TF exceeds that level, further analytical work may be required to determine whether the fluorine comes from PFAS or non-PFAS sources.

This distinction is important.

Therefore:

Total Fluorine testing should not be described as a standalone “PPWR certification.”

It is part of the analytical evidence that can support compliance assessment.

What Should Buyers Look for in a Test Report?

When reviewing PPWR chemical evidence, check:

Sample description
Does it clearly identify the packaging?

Material
PP, HDPE, LDPE or another material?

Test method

Regulatory reference

Component tested

Result

Report date

Do not rely only on a compliance icon or supplier statement.

UMETASS PPWR Testing

Selected PP and HDPE plastic packaging samples in our current compliance portfolio have undergone third-party testing covering:

Heavy Metals
Total Fluorine
PFAS

with the tested items reported as PASS.

Results apply to the submitted samples and stated test scope.

Conclusion

Article 5 compliance is ultimately about evidence, not marketing terminology.

For buyers sourcing plastic packaging into Europe, the most reliable approach is to connect:

material → product → component → test scope → report.