EU PPWR FAQs Updated August 2026 - Flipbook - Page 21
10) How can manufacturers prove compliance with Article 5(4) on the limit value for
heavy metals in packaging? NEW!
This is not a new obligation. Manufacturers already had to comply with this obligation under Article
11 of the repealed Directive on packaging and packaging waste10. To demonstrate compliance, it is
recommended to use the CEN report CR 13695-1/2000 Packaging - Requirements for measuring
and verifying the four heavy metals and other dangerous substances present in packaging and their
release into the environment - Part 1: Requirements for measuring and verifying the four heavy
metals present in packaging.
11) Does the obligation to minimise the presence of substances of concern (SoC) in
packaging apply to all economic operators?
The obligation applies to all packaging placed on the market, according to the definition in the
Regulation (Article 3(1), point (10)). The manufacturer placing packaging on the market or a
supplier, in case a manufacturer is a microenterprise, must make sure that the provisions are
complied with.
12) When does the obligation on minimisation of substances of concern (SoC) start to
apply for packaging that is not food-contact sensitive?
The general obligation to minimise SoC in Article 5(1) and the limits on four heavy metals in Article
5(4) apply to all packaging from 12 August 2026. The limits set in Article 5(5) for PFAS will apply
to food-contact materials only.
13) Member States may submit data on a substance they believe to be of concern before
31 December 2025. If Member States inform the Commission about new substances
of concern, will this information be accessible before the Commission delivers its
report in 2026?
According to Article 5(2) of the PPWR, Member States should inform the Commission about
relevant information on SoC before 31 December 2025. This information will be considered in the
development of the study. The monitoring of SoC is a permanent task for the Commission.
14) Does the derogation for glass packaging introduced by Commission Decision
2001/171/EC 11 in relation to heavy metal concentration levels in packaging and
packaging waste continue to apply?
Commission Decision 2001/171/EC continues to apply and has not been repealed by the PPWR.
This means that the packaging may exceed the concentration limit of 100 ppm by weight for the
sum of lead, cadmium, mercury and hexavalent chromium, when this exceedance is due to the
addition of recycled glass. No lead, cadmium, mercury or hexavalent chromium is allowed to be
intentionally introduced during the manufacturing process. The Commission may adopt delegated
10
European Parliament and Council Directive 94/62/EC of 20 December 1994 on packaging and packaging waste
11
Commission Decision of 19 February 2001 establishing the conditions for a derogation for glass packaging in
relation to the heavy metal concentration levels established in Directive 94/62/EC on packaging and packaging
waste (OJ L 62, 2.3.2001, pp. 20–21).
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