Heavy Metals & PFAS in Food Contact: PPWR 2026 Requirements

As we outlined in our earlier article on key PPWR milestones and deadlines, 2026 is going to be a turning point for the packaging industry,  with some of the first and most impactful obligations under the Packaging and Packaging Waste Regulation (PPWR) concerning chemical safety. In particular, Article 5 introduces strict requirements on heavy metals and PFAS substances, with a strong focus on food contact materials and their long-term impact on human health, reuse and recycling.

 

Heavy Metals Content: Scope and Limits

Article 5, point (4) of the PPWR extends heavy metals control to all packaging materials, not only food contact packaging. It requires testing for the combined content of cadmium (Cd), lead (Pb), mercury (Hg) and hexavalent chromium (Cr⁶⁺), with a strict limit of 100 mg/kg of packaging material.

 

Proposal for Metals

Packaging producers should perform heavy metals analysis in line with PPWR requirements. If the total concentration remains below 100 ppm, the material is considered compliant and can continue moving along the supply chain.

 

PFAS Substances Content: Why They Matter

PFAS (per- and polyfluoroalkyl substances) have been widely used for decades in packaging applications because of their grease resistance, water repellence, and thermal stability. Over time, however, scientific evidence has shown that many PFAS are persistent, bioaccumulative and potentially harmful to human health. They can build up in the body and the environment, earning the nickname “forever chemicals.”

 

PFAS Limits Under PPWR Article 5

PPWR Article 5, point (5) introduces a ban on placing food contact packaging on the market if PFAS exceed defined thresholds:

1. Targeted PFAS analysis (Polymeric PFAS are excluded from quantification in these two cases):
   • Any individual PFAS must be below 25 ppb
   • The sum of targeted PFAS must be below 250 ppb
2. Total fluorine (TF):
   • Total fluorine, including polymeric PFAS, must be below 50 ppm

If total fluorine exceeds 50 mg/kg, manufacturers, importers or downstream users must be able to demonstrate whether the fluorine originates from PFAS or from non-PFAS sources.

 

Testing and Chemical Compliance Requirements

From a compliance perspective, Article 5 brings together long-standing and new requirements:

1. Heavy metals:
   • Sum of Cd, Pb, Hg, Cr⁶⁺ < 100 mg/kg (aligned with Directive 62/1994)
2. PFAS in food contact materials (from 2026):
   • Individual targeted PFAS < 25 ppb
   • Sum of targeted PFAS < 250 ppb, including degradation of precursors where applicable
   • Total fluorine < 50 ppm

It is important to note that certain PFAS precursors, such as APFO used in PTFE production, may not be present in the final product but still need to be considered during testing, as required by the legislation.

 

Testing of Total Fluorine Content (TF)

Total fluorine testing is typically performed according to ISO 10304-1 and is used to assess compliance with Article 5(5)(c) of the PPWR.

A key challenge with TF testing is interpretation. An out-of-compliance result does not automatically identify the source of fluorine. Instead, it triggers the need for additional investigations to determine whether fluorine originates from PFAS or from other, non-restricted substances.

 

Testing of Individual PFAS Substances

Targeted PFAS analysis focuses on specific substances known to be commonly used in the packaging sector. While this approach cannot cover every PFAS on the market, it provides a practical and risk-based assessment aligned with regulatory expectations.

Pack-Lab offers a targeted PFAS testing package covering 46 commonly used substances in a single analysis, supporting compliance with PPWR Article 5, points (5)(a) and (5)(b).

 

 

How to Handle Current Materials

For materials already on the market, a structured approach is essential:

• Creating a detailed inventory of all in-house formulations and raw materials, including resins, masterbatches, inks, films, adhesives, and varnishes.
• Contacting suppliers to confirm whether any raw materials contain PFAS-family substances and request formal PFAS absence statements.
• For materials declared PFAS-free, verifying claims through total fluorine testing on high-volume formulations.
• For materials containing PFAS, combining total fluorine testing with targeted PFAS content analysis to confirm compliance with PPWR thresholds.

 

Managing New Materials and Product Development

For new product development, PFAS-containing raw materials should be avoided altogether, as they will need to be replaced after August 2026.

Best practices include:

1. Sourcing PFAS-free raw materials
2. Avoiding the intentional addition of PFAS during formulation
3. Verifying final materials through total fluorine testing
4. Documenting compliance with Article 5 in the final Declaration of Compliance

 

Legislative Context and Future Alignment

PFAS limits are already addressed under several EU regulations, including REACH (EC 1907/2006), POPs (EC 1021/2019), and Regulation EC 10/2011 on plastics in contact with food, where specific migration limits apply. Further harmonization is expected in the coming years, with PPWR acting as a key guide from 2026 onward.

 

Conclusion

The PPWR introduces a new level of chemical scrutiny for packaging, particularly for food contact materials. Heavy metals and PFAS are no longer peripheral compliance topics but central regulatory requirements that affect material selection, supplier management, testing strategies and documentation. Companies that act early, understand their formulations and invest in appropriate testing will be best positioned to navigate future obligations.