PPWR Article 5: What Businesses Need to Know About Substances in Packaging

PPWR Article 5 requires packaging placed on the EU market to be manufactured in a way that minimises the presence and concentration of substances of concern (SoC). It also establishes specific requirements for substances including lead, cadmium, mercury, hexavalent chromium and PFAS in food-contact packaging. The Packaging and Packaging Waste Regulation (PPWR) is changing how businesses assess packaging compliance in the EU. While much of the discussion around PPWR focuses on recyclability, recycled content, reuse and packaging waste, PPWR Article 5 addresses another critical area: substances in packaging.

For businesses, this means packaging compliance is no longer simply a question of what the packaging looks like or whether it can be recycled. Companies also need visibility into the substances present in their packaging materials and components and, importantly, the evidence needed to demonstrate compliance.

This guide explains PPWR Article 5, the key substance requirements, PFAS limits, documentation expectations and what businesses should do to prepare.

Key Takeaways:

• Article 5 makes chemical composition a packaging compliance issue. Packaging placed on the EU market must be manufactured so that the presence and concentration of substances of concern in packaging materials and components are minimised.
• “Substances of concern” goes beyond one specific chemical. Businesses need visibility into substances present across the packaging structure and its components not just the primary packaging material.
• Heavy metals have a defined limit. The combined concentration of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg.
• PFAS restrictions are particularly important for food-contact packaging. From 12 August 2026, food-contact packaging cannot be placed on the EU market when PFAS concentrations meet or exceed the thresholds specified in Article 5.
• Don’t assess only the main packaging material. Substances can be present in inks, coatings, adhesives, pigments, barrier layers and other packaging components, making component-level supplier data increasingly important.
• Supplier declarations alone may not provide the complete compliance picture. Businesses should establish a documented evidence chain connecting packaging → material/component → supplier → substance information → applicable requirement → compliance conclusion.
• Article 5 is not just a chemistry requirement—it is a data-management challenge. Companies need reliable visibility into packaging composition and supporting documentation across their packaging portfolio.
• Technical documentation matters. Businesses should be able to substantiate applicable substance-related compliance through the documentation required under the PPWR conformity-assessment framework.
• Food-contact packaging needs particular attention to PFAS data. The European Commission has specifically highlighted the PFAS restriction as one of the PPWR measures applying from 12 August 2026.

What Is PPWR Article 5?

PPWR Article 5 sets requirements for substances present in packaging and packaging components.

At a high level, Article 5 requires packaging placed on the EU market to minimise the presence and concentration of substances of concern. The requirement covers substances present in packaging materials or components and also considers potential impacts associated with emissions and waste-management outcomes.

Article 5 as a market-access requirement and compliance needs to be demonstrated through the technical documentation specified in Annex VII.

In simple terms: you need to know what is in your packaging and be able to demonstrate that it meets the applicable PPWR requirements.

What Does PPWR Article 5 Require?

There are three areas businesses should understand.

1. Substances of concern must be minimised

Packaging must be manufactured so that the presence and concentration of substances of concern are minimised. The regulation also requires the Commission to monitor substances of concern in packaging and packaging components.

2. Heavy-metal concentrations are restricted

The combined concentration of lead, cadmium, mercury and hexavalent chromium resulting from substances present in packaging or packaging components must not exceed 100 mg/kg, subject to the other chemical and food-contact legislation referenced in the Regulation.

3. PFAS are restricted in food-contact packaging

From 12 August 2026, food-contact packaging cannot be placed on the EU market when PFAS concentrations are at or above the limits specified in Article 5(5), subject to the conditions in the Regulation.

These requirements make substance data an important part of a company’s overall PPWR compliance strategy.

PPWR PFAS Requirements: What Businesses Need to Know

One of the most significant elements of PPWR Article 5 is the restriction on PFAS in food-contact packaging.

PFAS, or per- and polyfluoroalkyl substances, have historically been used in applications where resistance to grease, oil, water or heat is required. Because packaging can come into direct contact with food, PPWR introduces specific concentration limits.

From 12 August 2026, food-contact packaging cannot be placed on the EU market if it contains PFAS at or above the following thresholds:

The Regulation also provides that where total fluorine exceeds 50 mg/kg, relevant parties may need to provide evidence showing the quantity of fluorine attributable to PFAS or non-PFAS sources.

What does this mean operationally? Businesses selling food-contact products into the EU need to understand not only the packaging material itself but potentially the materials and components used to manufacture it.

• Coatings
• Films
• Paper and board
• Adhesives
• Inks
• Functional layers
• Closures and other packaging components

Understand what PPWR means for PFAS in food-contact packaging, the applicable thresholds, supplier data and compliance evidence businesses need to manage.

Read the Complete Guide to PFAS in Food Packaging

How Will PFAS Compliance Be Assessed?

A key development for businesses is the European Commission’s 2026 guidance on enforcement of the PFAS restrictions.

The Commission notes that there is currently no harmonised EU-level methodology for PFAS testing in food-contact packaging. It recommends a stepwise approach for enforcement based on available analytical methods.

The guidance describes total fluorine quantification as an initial step, followed by additional analysis where total fluorine exceeds the relevant threshold, and direct TOP analysis to assess compliance with the lower PFAS concentration limits where appropriate.

This is important because having a supplier declaration alone may not always provide the complete evidence trail a company needs.

Businesses should understand what evidence is available, which packaging it applies to, when it was generated and whether it supports the applicable compliance assessment.

What About Lead, Cadmium, Mercury and Hexavalent Chromium?

PFAS is not the only substance-related requirement under PPWR Article 5.

The Regulation establishes a combined limit for lead, cadmium, mercury and hexavalent chromium. The combined concentration resulting from substances present in packaging or packaging components must not exceed 100 mg/kg.

For packaging manufacturers and companies managing complex packaging portfolios, this creates an important data requirement:

Can you connect your substance evidence to the exact packaging material and component to which it applies?

That question becomes particularly important when the same packaging format has multiple suppliers, material specifications or production locations.

Who Needs to Pay Attention to PPWR Article 5?

PPWR Article 5 is particularly relevant to businesses involved in placing packaging on the EU market.

Manufacturers have a central role because they must ensure that packaging complies with the applicable requirements before placing it on the market. The EUROPEN guide states that manufacturers must carry out or arrange the required conformity assessment and prepare the technical documentation referred to in Annex VII.

Importers and distributors also have obligations under PPWR.

This means Article 5 should not be treated as an issue only for a chemical or laboratory team. It can involve multiple functions, including:

• Packaging
• Procurement
• Quality
• Sustainability
• Regulatory affairs
• Product compliance
• Suppliers
• Manufacturing
• Legal and compliance teams

Why Supplier Data Is Becoming Critical

One of the biggest practical challenges with PPWR Article 5 compliance is that substance information often sits outside the company’s central compliance system.

For example, procurement may have the supplier details; packaging teams may have the packaging specifications; suppliers may hold declarations and test reports; quality teams may maintain laboratory results; and compliance teams may determine whether the evidence is sufficient.

The problem arises when these records are not connected.

A company may have a PFAS test report, for example, but still struggle to answer:

• Which packaging SKU does the report apply to?
• Which supplier provided the material?
• Which component was tested?
• When was the test performed?
• Does the evidence apply to the current formulation?
• Is the packaging food-contact packaging?
• Has the material or supplier changed?
• Where is the supporting documentation?

This is why PPWR compliance is increasingly a data-management challenge as well as a regulatory challenge.

PPWR compliance starts with reliable supplier data. Learn how to collect packaging specifications, material information, supplier declarations and compliance evidence through a structured supplier engagement process.

Read the Complete Guide to Supplier Engagement for PPWR

PPWR Article 5 and Technical Documentation

A critical part of Article 5 compliance is evidence.

Compliance with Article 5 is a market-access condition and needs to be demonstrated through technical documentation under Annex VII of PPWR.

The wider economic-operator requirements also state that manufacturers must prepare and retain the relevant technical documentation and EU Declaration of Conformity for specified periods.

This creates a practical evidence chain:

Packaging SKU → Material & Component Data → Supplier Information → Substance / Composition Data → Test Reports & Declarations → Compliance Assessment → Technical Documentation

The objective is not simply to collect more documents. The objective is to ensure that every relevant piece of evidence can be traced back to the packaging it supports.

PPWR compliance requires more than collecting packaging data it requires structured technical documentation and evidence to support your compliance decisions.

Read the Complete Guide to PPWR Technical Documentation

What Should Businesses Collect From Suppliers?

To prepare for PPWR Article 5, companies should review the substance information they receive from suppliers.

Depending on the packaging and applicable requirements, businesses may need to manage information such as:

• Material specifications
• Component composition
• Substance declarations
• PFAS-related evidence
• Fluorine test results where applicable
• Heavy-metal test results
• Food-contact status
• Supplier declarations
• Laboratory reports
• Certificates
• Regulatory references
• Evidence version and date

The important point is to establish a controlled evidence trail rather than relying on disconnected PDFs and emails.

How TraceX Can Help With PPWR Article 5 Compliance

TraceX PPWR Solutions can help businesses create a structured data and evidence layer for packaging compliance.

Instead of managing packaging information, supplier documents and compliance evidence across disconnected systems, teams can connect these records through a centralised workflow.

TraceX can help you:

• Centralise packaging information — Maintain structured records for packaging SKUs, materials and components.
• Connect supplier evidence — Link declarations, certificates and test reports to the relevant packaging records.
• Track substance-related information — Maintain structured data related to packaging composition and applicable substance requirements.
• Build an evidence trail — Connect packaging records with the supporting documentation used for compliance assessments.
• Improve audit readiness — Make it easier to identify the evidence supporting a particular packaging compliance decision.

Packaging → Material → Component → Supplier → Evidence → Assessment → Compliance Record

TraceX does not replace laboratory testing or regulatory interpretation. Instead, it can help provide the data and traceability infrastructure needed to organise the information and evidence behind your PPWR compliance process.

PPWR Article 5 Compliance Checklist

Before placing packaging on the EU market, businesses should ask:

Packaging data

• Do we have a complete inventory of packaging placed on the EU market?
• Can we identify the materials and components used in each packaging format?

Substance data

• Do we have visibility into relevant substances present in packaging?
• Can we identify packaging that falls within food-contact applications?
• Do we have appropriate evidence relating to PFAS where applicable?
• Can we demonstrate compliance with the heavy-metal concentration requirement?

Supplier evidence

• Are supplier declarations linked to specific packaging materials?
• Are test reports linked to the correct packaging or component?
• Can we identify outdated or missing evidence?

Compliance documentation

• Can we trace a compliance assessment back to its supporting evidence?
• Can we retrieve the documentation needed to support the Annex VII technical file?
• Do we have a controlled process for updating evidence when materials or suppliers change?

If the answer to several of these questions is no, your organisation may have a data-readiness gap even if the packaging itself is technically compliant.

What Happens Next for PPWR Article 5?

Article 5 is not a static requirement.

The Regulation requires the European Commission, assisted by the European Chemicals Agency, to prepare a report by 31 December 2026 on substances of concern in packaging and packaging components. The report will consider their effects on reuse and recycling as well as chemical safety.

The Commission is also required to evaluate Article 5 and the design-for-recycling criteria by 12 August 2033.

For businesses, this means substance management should be treated as an ongoing compliance process, rather than a one-time documentation exercise.

PPWR Article 5 changes the compliance question from “What is our packaging made of?” to “Can we demonstrate what is in it?”

The regulation requires businesses to minimise substances of concern in packaging and establishes specific requirements for substances including heavy metals and PFAS in food-contact packaging.

For companies with large packaging portfolios, the challenge is not simply understanding the regulation.

It is connecting the information required to demonstrate compliance:

Packaging → Material → Component → Supplier → Substance Data → Test Evidence → Compliance Assessment → Technical Documentation

That is where a structured digital compliance approach can make a difference.

Frequently Asked Questions (FAQ’s)