EU Packaging Regulation - Heavy Metals Concentration Limit Effective August 2026

Under Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation - PPWR), all packaging and packaging components placed on the EU market must comply with strict heavy metals concentration limits starting 12 August 2026.

The regulation establishes that the combined concentration of four heavy metals—lead (Pb), cadmium (Cd), mercury (Hg), and hexavalent chromium (Cr VI)—resulting from substances present in packaging or packaging components shall not exceed 100 mg/kg (100 ppm by weight). This limit applies without prejudice to existing restrictions under REACH Annex XVII (Regulation EC 1907/2006) or food contact material regulations (Regulation EC 1935/2004), meaning any stricter requirements in those regulations continue to apply.

While this requirement continues an existing obligation from the previous Packaging Directive, the new PPWR introduces enhanced enforcement mechanisms and documentation requirements that all economic operators must address.

The concentration limit applies to all types of packaging placed on the EU market, including primary, secondary, and tertiary packaging, as well as all packaging components and materials regardless of whether they are designed for single-use or reusable systems. All economic operators in the packaging supply chain—from material manufacturers to product distributors—share responsibility for ensuring compliance.
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With six months remaining until the application date, companies should engage with their packaging suppliers to obtain test reports and declarations of conformity confirming heavy metals content. Material specifications and supplier agreements should be reviewed and updated to explicitly include PPWR compliance obligations. Technical documentation demonstrating compliance with the concentration limits must be prepared and maintained for regulatory verification purposes.