The Packaging and Packaging Waste Regulation sets a combined concentration limit for four specified metals: lead, cadmium, mercury and hexavalent chromium. Article 5(4) says their sum in packaging or packaging components must not exceed 100 mg/kg. Reading the figure as a separate allowance for each metal changes the rule. [1]
This is a concentration requirement with a defined substance list and sample object. It is not a universal declaration that a package is free of heavy metals, free of all hazardous substances or suitable for contact with food.
Read the sum before reading the certificate heading
The specified result concerns the sum of the four named concentrations. A report needs enough identification to connect its results to the packaging or component being assessed. If the document gives four separate values but no interpretation of their combined result, a “pass” heading alone does not explain the comparison.
Hexavalent chromium is also a specific chemical description. A result labelled only “chromium” should not silently be presented as a measurement of chromium in that oxidation state. The analytical method and reported scope need to establish what was measured; the article does not select or validate a laboratory method. [1]
| Question | Rule or evidence | Important boundary |
|---|---|---|
| Covered substances | Lead, cadmium, mercury and hexavalent chromium | Total chromium is not the same analytical description as hexavalent chromium |
| Threshold | Combined concentration must not exceed 100 mg/kg | The limit is not a separate 100 mg/kg allowance for each substance |
| Object | Packaging or packaging components | Identify what the reported sample represents |
| Other rules and derogations | Article 5 and relevant retained decisions | Do not infer blanket chemical compliance from this one result |
A worked sum is an illustration, not a test
Suppose an illustrative component has reported concentrations of 20, 5, 2 and 10 mg/kg for the four specified substances. Their arithmetic sum is 37 mg/kg. The comparison is to the combined 100 mg/kg ceiling, not to four independent ceilings. These invented values explain the calculation only; they are not measurements from a real material or evidence that a commercial pack complies.
The same arithmetic cannot fix incompatible samples, missing analytical coverage or an unclear reporting basis. Before adding numbers, the evidence must identify the specimen, units and method sufficiently to support the intended comparison.
The chemical framework remains wider
Article 5(4) expressly preserves relevant REACH restrictions and food-contact restrictions and specific measures. Other paragraphs address other substances and regulatory mechanisms. Satisfying the four-metal concentration requirement therefore does not establish compliance with those separate controls. [1]
The regulation also contains powers and transition provisions concerning derogations and existing decisions. A claimed exception needs its own applicable legal basis and conditions. Neither “recycled material” nor “glass packaging” should be treated as an unexplained universal exemption in a supplier file.
A useful statement identifies its boundary
An evidence-based statement should identify the packaging or component, the specified substance coverage, result units and applicable version of the rule. It should distinguish a test result from a broader conformity conclusion and preserve any conditions on a relevant derogation.
That boundary is especially useful when one document is reused for several purposes. A four-metal report may answer this concentration question while leaving food-contact migration, PFAS restrictions, recycling performance and environmental marketing claims unanswered. Keeping those conclusions separate makes the document more useful, not less.
The wider implementation context is covered in our PPWR overview; the present guide isolates the provision identified above.
Sources
Sources checked 21 October 2026. Legal text, official interpretation and editorial examples are distinguished above. No individual product or business conformity assessment was performed.
- European Parliament and Council / Official Journal via BOE. Regulation (EU) 2025/40 on packaging and packaging waste. 19 December 2024; OJ 22 January 2025. Locator: Article 5(4), (6)–(8); Articles 70–71. Relevant full original provisions read in the official Spanish rendition; English explanation is an editorial paraphrase, not an official translation.
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