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PPWR Article 5: Requirements for substances in packaging

Article 5 of Regulation (EU) 2025/40, the EU Packaging and Packaging Waste Regulation.

Applies fromAugust 12, 2026
BindsManufacturers, importers, non-EU producers
EvidenceLocked read in the EUR-Lex text

What it requires

Requires the presence and concentration of substances of concern in packaging to be minimized, and from August 12, 2026 restricts PFAS in food-contact packaging at three limits under Art. 5(5): 25 ppb for any individual PFAS and 250 ppb for the sum of PFAS, both by targeted analysis excluding polymeric PFAS, and 50 ppm for total PFAS including polymeric PFAS. Art. 5(4) also limits the sum of lead, cadmium, mercury, and hexavalent chromium in packaging or its components to 100 mg/kg. Where total fluorine exceeds 50 mg/kg, the manufacturer, importer or downstream user under Regulation (EC) No 1907/2006 must on request provide the packaging's manufacturer or importer with proof of the amount of fluorine measured as PFAS or non-PFAS. Commission guidance (Notice C/2026/3084) describes a stepwise test that starts with total fluorine, where a sample under 50 mg/kg could be considered compliant. The same guidance says the PFAS limits carry no exception for packaging containing recycled material.

This is a plain-English summary for planning, not legal advice, and it is not a substitute for the text. Read Article 5 in full at EUR-Lex, and verify against the Official Journal before any compliance decision.

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