A heavy-metal test report that shows four compliant metals can still describe a non-compliant pack. Article 5(4) of Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation (PPWR) — caps the sum of lead, cadmium, mercury and hexavalent chromium at 100 mg/kg across the packaging and each of its components. It is an aggregate figure, not four individual limits, and the difference decides whether a compliance file holds up. The limit carries over from the old Packaging Directive with no phase-in date: a pack on the shelf that exceeds it is already unlawful.
What the limit actually says
- Four metals, one number. Lead, cadmium, mercury and hexavalent chromium are added together and compared against 100 mg/kg. There is no separate ceiling for any one of them.
- The unit is the whole pack, and each component. The ceiling applies to packaging and to packaging components, so a compliant box and a compliant insert can still sum to a non-compliant pack.
- Food contact is irrelevant. Unlike the PFAS restriction, this one is not limited to food-contact packaging. It applies to packaging generally.
- No transition period. The requirement is inherited, not new, which is why it has no 12 August 2026 start date attached to it.
Where the metals come from
| Component | Typical route in | What to ask for |
|---|---|---|
| Inks and pigments | Certain inorganic pigments, especially yellows, oranges and reds, and some drying agents | A metal-content statement per ink, by colour, not a general print declaration |
| Adhesives | Stabilisers and catalysts used in some formulations | Component-level data, since the adhesive is usually a small share of mass but not of risk |
| Recycled fibre | Legacy metals carried in from recovered paper streams | Grade-specific evidence — recycled content does not inherit the virgin grade's result |
| Metallic foils and coatings | Pigments and additives in the coating or the metallised layer | A summation across the coated layer and the substrate |
The pattern is that the mass of the component tells you nothing about its contribution. An ink at a few percent of pack weight can carry most of the metal load.
How the summation is done
The arithmetic is the part that fails audits. Each component is measured, converted to a concentration in the component, then converted again to its contribution to the whole pack by mass, and only then added up.
Worked shape of the calculation: component metal concentration × component share of pack mass = contribution. Sum the contributions across all components. Compare the total against 100 mg/kg.
A component at 300 mg/kg that is 5% of pack mass contributes 15 mg/kg. The same concentration in a component that is 40% of pack mass contributes 120 mg/kg — over the limit on its own.
Two consequences follow. First, a component-level pass is not a pack-level pass. Second, the summation has to be redone whenever the bill of materials changes — a new ink, a new adhesive or a switch to recycled fibre resets the calculation.
FAQ
Is the limit per metal or in total?
In total. Lead, cadmium, mercury and hexavalent chromium are summed and the total must not exceed 100 mg/kg. Four results each under 100 mg/kg can still exceed the limit between them.
Does it apply to the ink and the adhesive, or only to the paper?
To the packaging and its components. Ink, adhesive, coating and any non-fibre parts are all in scope, and the assessment is of the pack as placed on the market.
Why does recycled fibre need separate evidence?
Because recovered paper streams are one of the routes by which legacy metals enter a pack. A recycled grade's figure is its own figure and cannot be inferred from the virgin grade it replaces.
Does a supplier declaration cover it?
A dated declaration with the underlying component data is a reasonable starting point. A declaration without the data behind it does not show the summation, and the summation is what the limit is set against.
Browse the range
The regulatory background, including how Article 5 sits alongside the PFAS thresholds, is set out in our PFAS-free packaging white paper. For constructions where the component list is short and documented, see the water-based barrier coating paper range and the wider materials library, or the functional label range where ink and adhesive selection carries most of the compliance weight. Tell us the destination market and the pack construction, and we will confirm the grade and the documentation you need. Compliance documentation is provided offline on request; we do not publish certificate numbers online.
More in this series: how PFAS is tested in food packaging · recyclability grades A, B and C · EPR and the authorised representative