PPWR Heavy Metals: The 100 mg/kg Limit and What to Ask a Supplier

Last reviewed 23 October 2026 · Written by HuanCheer New Protection Material, Jiangsu, China

The 100 mg/kg heavy-metal limit has been mandatory for every packaging material since 12 August 2026. What buyers should actually ask a supplier for — and what a useless answer looks like.

What the limit actually says

The limit is a sum, not four separate limits. Lead + cadmium + mercury + hexavalent chromium, taken together, must not exceed 100 mg/kg (0.01% by weight) in the packaging or any of its components. A packaging unit that is 60 mg/kg lead and 55 mg/kg cadmium fails, even though neither metal breaches 100 on its own.

Three details matter in practice:

• It is per component, not just per unit. Inks, coatings, adhesives, closures and labels are components. A compliant board with a non-compliant print is a non-compliant unit.
• It replaced a patchwork. Directive 94/62/EC set the same 100 mg/kg figure, but member states applied it with different derogations and different enforcement. PPWR unified it to a single threshold with no national variation.
• There is no "non-food contact" relief. The limit covers all packaging regardless of whether it touches food. This is the part that catches transport packaging buyers out, because most of the PPWR commentary they read is about food-contact PFAS.

Where paper stands

Kraft paper from a virgin or well-controlled recycled furnish usually sits far below 100 mg/kg for all four metals. That is a material property, not a compliance position, and the distinction matters.

The realistic risk points for a paper-based cushioning product are not the paper itself:

What to ask a supplier, in this order

Most buyers ask "are you compliant?" and accept "yes". That is not a question a supplier can answer honestly across an unknown product range, and it produces nothing a compliance team can file. These four questions do:

1. Which standard was the test run against? The successor to the 94/62/EC method (EN 13428 lineage, or the equivalent national method) on the base material. A report against an unrelated standard tells you nothing about Article 5(4).
2. What was tested — base material or finished unit? A report on 80 gsm kraft says nothing about the same kraft after printing. Ask whether the tested sample included print, adhesive and coating, and if not, what covers those.
3. How old is it? A test report is a snapshot of a production period. Ask for the date and for the retest interval the supplier works to. A 2019 report on a 2026 shipment is a gap, not evidence.
4. Is the underlying data available, or only a certificate? A certificate with no test data cannot be checked. What you want is the laboratory report — issuing lab, method, sample description, results per element.

What it becomes in your technical file

Under PPWR, the heavy-metal result is one input to the technical documentation that supports the EU declaration of conformity. It is not a standalone certificate you can wave at an inspector. In a workable file it sits alongside the bill of materials, the recyclability assessment and the minimisation record, and it has to be traceable to a specific product specification rather than to "our paper range".

Practically, that means the useful thing to obtain from a supplier is not a document titled "compliance certificate" but a test report whose sample description matches the product you are buying.

Timing: why this is worth doing before the order, not after

A heavy-metal test is relatively cheap and quick compared with a PFAS screen. That is exactly why it should be requested at sampling stage: it costs almost nothing to ask for when you are already asking for samples, and it becomes an awkward, schedule-blocking request once goods are on the water and a customs authority or a retail compliance team is asking.

The failure mode is not a rejected shipment. It is a buyer's own compliance team refusing to sign the declaration of conformity because one input document is missing — at which point the goods are already in a warehouse in Rotterdam.