Article 5 of the PPWR: Restrictions for Certain Substances of Concern

Article 5 of the EU Packaging and Packaging Waste Regulation (PPWR) sets out requirements for the presence and minimization of substances of concern in packaging. The regulation pursues several key objectives: reducing the environmental impact of packaging, increasing consumer safety, and improving material and food safety. At the same time, it ensures that packaging can be safely recycled and that no harmful substances enter the circular economy. The focus is primarily on heavy metals and PFAS (per- and polyfluoroalkyl substances). While the regulation of heavy metals is based on established testing methods and decades of experience, the handling of PFAS presents a greater challenge due to their vast number and complex detectability. 

The new requirements enter into force on August 12, 2026, and apply to all packaging placed on the market from that date onward. 

Article 5 aims to limit the presence of certain substances of concern in packaging and minimize their impact on the environment, recycling, and human health. The main focus is specifically on heavy metals and PFAS. 

The PPWR (EU 2025/40) establishes binding PFAS limits from 12 August 2026 (Article 5 paragraph 5). Food-contact packaging may only be placed on the market if the following limits are met: 

• 25 ppb (parts per billion) for any PFAS5 
• 250 ppb for the sum of PFASs6 
• 50 ppm (parts per million) for PFASs if the total fluorine content exceeds 50 mg/kg7 

These limits are not merely recommendations but firmly embedded in Article 5 of the PPWR and therefore mandatory for manufacturers of food-contact packaging within the definition of the PPWR8. Failure to comply may result in sanctions, including sales bans or costly product recalls. 

The PPWR’s strict PFAS limits pose major challenges for companies in practice. Analytical testing is technically demanding, methods are not yet harmonized, and laboratory results can vary. Fully conclusive measurements for all relevant substances are often not possible today. Companies must therefore invest considerable effort to obtain and document information across the entire supply chain. Industry and stakeholder groups have communicated these difficulties to the European Commission. 

In response, the Commission has developed a guidance document describing a stepwise testing approach intended to simplify practical implementation. This guidance is currently only in draft form, and has not been officially published. It is not legally binding, but instead serves as a pragmatic orientation tool until robust testing methods are available. 

The recommended approach proposes to first determine the total fluorine content of a packaging material. If it is below 50 ppm, no further analysis of individual PFAS would be required. If the value exceeds 50 ppm, testing for organic fluorine would be carried out. If this is below 50 ppm, no further analysis would be required. Only if this threshold is exceeded would targeted testing of individual PFAS become necessary. 

This process is designed to reduce effort and enable structured prioritization but does not replace legal assessment. 

Crucially, this logic has no legal effect. From a technical perspective, it does not provide absolute certainty, since a total fluorine content below 50 ppm does not rule out that individual PFAS may still exceed the specific 25 ppb limit. The approach can therefore help prioritize testing, given that not all thousands of PFAS can currently be reliably detected individually. However, it does not replace a comprehensive assessment of all relevant substance thresholds. 

Independent of the technical limitations, the question of testing responsibility arises. Article 5 of the PPWR sets only limit values, neither mandatory test steps nor responsibilities within the supply chain are defined. There is no testing obligation. Responsibility for complying with the limits remains with the respective producer as defined by the PPWR, regardless of whether an analysis is carried out. 

In short: the conditional testing pathway is a helpful tool for orientation and prioritization, but it is not a legal basis. It can support risk assessment but neither constitutes a binding regulation nor provides liability protection. As long as harmonized and widely accepted test methods are lacking, the practical implementation of PFAS requirements remains challenging, and many detailed questions remain unresolved. 

Greiner Packaging is preparing extensively for this new situation. The objective is to secure and make essential information available at an early stage. The work includes, among other things: 

• ongoing, structured inquiries to upstream suppliers regarding heavy metals, PFAS, and other substances of concern in accordance with Article 5 of the PPWR 
• building a system that provides complete, traceable, product-specific data 
• close collaboration with experts who monitor developments in analytics and regulation 
• internal training that ensures clear, aligned, and technically sound communication
• alignment with European recommendations, combined with a consistent focus on legally binding requirements 

These measures gradually create a framework that not only covers legal requirements but also facilitates practical implementation. 

In the coming months, it is expected that the testing landscape within the supply chain will continue to evolve and that more clarity will emerge regarding the practical implementation of the PPWR’s substance limits. In particular, it remains to be seen how the European Commission will interpret the new requirements and what it will specify with regard to practical implementation and mandatory compliance. These clarifications will likely provide further orientation and contribute to a more uniform assessment. 

The entire industry is thus navigating a process that is technically and organizationally demanding. At the same time, this development offers an opportunity to design packaging more responsibly in the long term. Greiner Packaging is actively shaping this transition and creating structures that can grow and adapt flexibly to new requirements. 

Article 5 of the PPWR combines established practice with new challenges: while the regulation of heavy metals rests on stable foundations, PFAS regulation leads into a field that is still evolving. Through consistent information gathering, precise documentation, and close cooperation with expert bodies, Greiner Packaging is building a reliable foundation - not only for the company itself but for the entire industry. 

For the packaging sector, this means above all that the next few years will be a period of transition and joint clarification of open issues. Although the regulation makes manufacturers of food-contact packaging responsible for compliance with applicable limits, in practice this can only be achieved through transparent cooperation, reliable data, and aligned processes across the entire supply chain. 

Greiner Packaging works closely with customers, partners, and experts to shape the practical feasibility of the new requirements, develop solutions, and support compliance with the limits. In this way, safety, predictability, and reliable implementation of the PPWR requirements are to be ensured. 

^{Disclaimer: This article is provided for general information purposes only and does not constitute legal advice. The information given in this article reflects our current state of knowledge at the time of publication and may be subject to change.}