Substances in packaging
Includes the combined limit for lead, cadmium, mercury and hexavalent chromium, plus specific PFAS thresholds for food-contact packaging from 12 August 2026.
Regulation (EU) 2025/40 knowledge guide
EU PPWR: Key Dates, Chemical Limits & Packaging Testing
The Packaging and Packaging Waste Regulation (PPWR) entered into force on 11 February 2025 and generally applies from 12 August 2026. This guide explains the main phased requirements, Article 5 substance limits, key 2030 targets and how laboratory testing can be arranged for selected PPWR parameters.
PPWR requirements phase in on different dates. Match the requirement to the packaging type and target market date.
Entered into force11 February 2025
General application12 August 2026
Heavy metals100 mg/kg combined
Food-contact PFAS25 ppb / 250 ppb / 50 ppm
What the regulation covers
The main PPWR requirements do not start at the same time
Regulation (EU) 2025/40 covers packaging and packaging waste placed on the EU market. Key areas include substances in packaging, recyclability, recycled content, packaging minimisation, labelling, reuse and excessive packaging.
Recyclable packaging
Design-for-recycling and recyclability-at-scale requirements phase in from 2030 and 2035 under the timing rules in the Regulation.
Recycled content in plastic packaging
Minimum recycled-content percentages apply by packaging type, with 2030 and 2040 targets and timing linked to the relevant implementing act.
Minimisation, labelling and empty space
Later phases introduce packaging minimisation, harmonised material-composition labels and limits on unnecessary empty space.
Article 5 chemical requirements
Heavy-metal and PFAS concentration limits
Article 5 provides specific concentration thresholds for substances in packaging. The heavy-metal requirement is a combined total across four metals; it is not a separate 100 mg/kg limit for each metal.
≤ 100 mg/kg
Combined concentration limit — Article 5(4)
The sum of lead, cadmium, mercury and hexavalent chromium resulting from substances present in packaging or packaging components must not exceed 100 mg/kg.
PbLeadIncluded in the combined 100 mg/kg total.
CdCadmiumIncluded in the combined 100 mg/kg total.
HgMercuryIncluded in the combined 100 mg/kg total.
Cr(VI)Hexavalent chromiumIncluded in the combined 100 mg/kg total.
How to read this limit: the four listed metals are added together for Article 5(4). PPWR does not assign a separate 100 mg/kg allowance to each metal.
| Parameter | Threshold | Regulatory description |
|---|---|---|
| Any PFAS | 25 ppb | Measured with targeted PFAS analysis; polymeric PFAS are excluded from quantification. |
| Sum of PFAS | 250 ppb | Measured as the sum of targeted PFAS analysis, where applicable with prior degradation of precursors; polymeric PFAS are excluded from quantification. |
| PFAS including polymeric PFAS | 50 ppm | Article 5(5)(c). If total fluorine exceeds 50 mg/kg, the Regulation also sets an evidence requirement concerning the measured PFAS or non-PFAS fluorine content. |
Article 7
2030 minimum recycled-content targets for plastic packaging
By 1 January 2030, or three years from the date of entry into force of the relevant implementing act if that is later, plastic parts of packaging are subject to minimum post-consumer recycled-content targets by packaging type and format.
PET as the major component, excluding single-use plastic beverage bottles.
Plastic materials other than PET, excluding single-use plastic beverage bottles.
Minimum recycled content recovered from post-consumer plastic waste.
Applies to plastic packaging outside the three categories listed above.
Source: Regulation (EU) 2025/40, Article 7.
Implementation timeline
Key PPWR dates for planning
The dates below show major milestones. Some obligations use a “whichever is later” rule linked to an implementing or delegated act, so the Regulation and current Commission guidance should be checked for the specific packaging and requirement.
11 February 2025
Regulation (EU) 2025/40 entered into force.
12 August 2026
The PPWR generally applies. Article 5(5) PFAS limits for food-contact packaging apply from this date.
12 February 2028
Economic operators filling sales packaging must reduce empty space to the minimum necessary for packaging functionality, including product protection.
12 August 2028 or later
Harmonised material-composition labelling applies from 12 August 2028 or 24 months from the entry into force of the relevant implementing acts, whichever is later.
From 1 January 2030
Major provisions phase in, including packaging minimisation. Design-for-recycling, plastic recycled-content targets and the 50% maximum empty-space ratio for grouped, transport and e-commerce packaging have additional timing rules tied to implementing or delegated acts.
From 1 January 2035
The recyclable-at-scale condition is added, subject to the timing rule in Article 6.
UTS laboratory testing support
How a PPWR-related laboratory testing plan can be arranged
For PPWR requirements that can be evaluated by laboratory testing, UTS can coordinate the testing scope with a laboratory based on the packaging material, component, intended use, requested clause, sample quantity and required reporting limit.
Packaging scope
Identify the packaging material and the components that may require separate testing, such as coatings, inks, adhesives or inserts.
PPWR parameter
Confirm the relevant article and requested analytes, for example the Article 5(4) heavy metals or an Article 5(5) PFAS parameter.
Method & samples
The laboratory confirms the analytical method, reporting limit, sample preparation, sample quantity, cost and turnaround time.
Testing & report
UTS coordinates sample submission and laboratory testing and provides the laboratory report for the agreed test scope.
Information needed to prepare a testing quotation
- Packaging material and component list, including coatings, inks and adhesives where relevant.
- Intended use, including food-contact status and contact conditions where applicable.
- Requested PPWR article, parameter or analyte list.
- Available sample quantity, target completion date and preferred report language.
Common questions
PPWR requirements and testing
These questions focus on the regulation itself and on the information needed when laboratory testing is requested.
When did PPWR enter into force and when does it generally apply?
Regulation (EU) 2025/40 entered into force on 11 February 2025 and generally applies from 12 August 2026. Individual requirements can use later dates.
Is the heavy-metal limit 100 mg/kg for each metal?
No. Article 5(4) sets one combined limit: lead, cadmium, mercury and hexavalent chromium are added together, and the total must not exceed 100 mg/kg.
What PFAS thresholds apply to food-contact packaging?
From 12 August 2026, Article 5(5) sets thresholds of 25 ppb for any PFAS by targeted analysis, 250 ppb for the sum of targeted PFAS and 50 ppm for PFAS including polymeric PFAS, subject to the exact wording and conditions of the Regulation.
What recycled-content targets apply from 2030?
Article 7 sets 30% for contact-sensitive PET packaging, 10% for contact-sensitive non-PET plastic packaging, 30% for single-use plastic beverage bottles and 35% for other plastic packaging, with the applicable start date subject to the timing rule in Article 7.
Can UTS arrange PPWR-related laboratory testing?
Yes. UTS can coordinate a testing plan and laboratory work for selected PPWR-related parameters, subject to method, sample and scope confirmation.
What information is needed for a testing plan?
Provide the packaging material and component list, intended use, requested PPWR article or analytes, available sample quantity and required completion date.
Official references
- Regulation (EU) 2025/40 on packaging and packaging waste
- European Commission — Packaging and packaging waste
- European Commission guidance document for Regulation (EU) 2025/40
Content reviewed on 25 August 2026. PPWR provisions can depend on later implementing or delegated acts, so the current official text should be checked when defining a test scope.
Laboratory testing support
Arrange testing for selected PPWR parameters
Send the packaging materials, intended use, requested PPWR parameter or analyte list, available sample quantity and required date. UTS can coordinate scope confirmation, quotation and laboratory testing.
Email: inquiry@utsinspection.com