PPWR Heavy Metals: Is a Supplier Statement of "< 100 ppm" Enough Evidence for Article 5(4)?
Is a Supplier Statement of "< 100 ppm" Enough to Show That Packaging Meets Article 5(4)?
Not by itself. A "< 100 ppm" line restates the limit of Article 5(4) without showing how it was met. Under Article 5(6), compliance with Article 5(4) is demonstrated in the Annex VII technical documentation. A supplier statement becomes usable evidence there once it names the component, the four metals, its basis, its date and the material covered.
A chemicals customer wrote to us on 2 and 4 September 2026 that suppliers "typically state compliance simply as '< 100 ppm' instead of providing exact measured numbers", attaching two supplier statements, one of them in German. On 20 August 2026, another user asked "where do test reports, lab certificates actually live". Both questions are answered here for Article 5(4) only. PFAS and the minimisation duty are covered in our overview of Article 5 substances of concern, and blanket letters versus packaging-level evidence in what counts as supplier evidence.
Three roles read the same statement. The manufacturer, often the brand owner, draws up the technical documentation under Article 15(2). The importer ensures that the manufacturer has drawn it up, under Article 18(2)(a). The converter is usually the supplier, defined in Article 3(1)(16) as any natural or legal person that supplies packaging or packaging material to a manufacturer.
Key Facts
- Under Article 5(4), the sum of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg.
- Under Article 5(4), the 100 mg/kg limit on the sum of lead, cadmium, mercury and hexavalent chromium applies in the packaging or in any packaging component, and concentrations are never added up across components.
- From 12 August 2026, the sum of lead, cadmium, mercury and hexavalent chromium in packaging may not exceed 100 mg/kg.
- Regulation (EU) 2025/40 applies to all packaging, regardless of material, whether household, commercial or industrial, under Article 2(1).
- The four statements above are confirmed by our dated PPWR referential (baseline reviewed 15 September 2026). The other provisions cited here are linked where they are read and listed under "What does the referential not confirm?".
What Exactly Does Article 5(4) Limit?
Under Article 5(4), the sum of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components must not exceed 100 mg/kg. The Regulation writes the limit in mg/kg. One part per million by mass is one milligram per kilogram, so "100 ppm" by mass names the same number.
The Article 5(4) heavy-metal limit is a ceiling on the sum of the concentrations of the four metals in packaging or packaging components. The figure is a sum across the four metals, not a limit per metal. A statement that each metal is below 100 mg/kg leaves the sum open, because four values just under 100 mg/kg add up to nearly 400 mg/kg.
From 12 August 2026, the sum of lead, cadmium, mercury and hexavalent chromium in packaging may not exceed 100 mg/kg. Article 5(4) carries no date of its own: the date is the one from which Article 71 applies the Regulation. Article 5(4) applies without prejudice to the restrictions of Annex XVII to Regulation (EC) No 1907/2006 and, where applicable, to the food-contact rules of Regulation (EC) No 1935/2004.
Two derogations adopted under the repealed Directive 94/62/EC carry over. Article 70(3) keeps in force Commission Decisions 2001/171/EC and 2009/292/EC, which set conditions for derogations for glass packaging and for plastic crates and plastic pallets, until delegated acts under Article 5(8) repeal them. Article 5(7) allows a delegated act to lower the limit. Article 5(8) allows delegated acts only to amend the derogations of those two Decisions. Our referential does not confirm whether any such act has been adopted.
Why Does the Worst Component Decide?
Article 5(4) of Regulation (EU) 2025/40 limits the sum of lead, cadmium, mercury and hexavalent chromium to 100 mg/kg in the packaging or in any packaging component, and concentrations are never added up across components: the worst component decides. A concentration is a ratio of metal to material, so each component carries its own figure.
The Regulation defines two kinds of packaging component, the integrated component of Article 3(1)(43) and the separate component of Article 3(1)(44). A closure, a label, a liner or a handle is read against the limit on its own. The figures below are illustrative, not measurements.
| Component | Mass | Sum of the four metals | Against 100 mg/kg |
|---|---|---|---|
| Bottle body | 40 g | 5 mg/kg | Below |
| Coloured closure | 3 g | 180 mg/kg | Above |
| Printed label | 1 g | 20 mg/kg | Below |
| Whole bottle, averaged by mass | 44 g | about 17 mg/kg | Not the test |
Adding the three concentrations gives 205 mg/kg, a figure with no physical meaning. Averaging them by mass gives about 17 mg/kg, a figure that hides the closure. The closure is a packaging component above 100 mg/kg, and the bottle does not meet Article 5(4) until the closure does. A "< 100 ppm" statement for the bottle body says nothing about the closure or the label. See also our article on the unit of PPWR conformity.
What Does a "< 100 ppm" Statement Cover, and What Does It Leave Open?
A "< 100 ppm" statement covers a conclusion: the issuer says the limit is met. A threshold statement is a supplier document that asserts a result without the values or the method behind it. A threshold statement leaves open the component and material covered, the sum or single metal concerned, how the result was obtained and when.
| Question | A bare "< 100 ppm" line | A usable statement |
|---|---|---|
| Which component? | None named, or a product family | The component and its material, as you buy them |
| Which metals? | "Heavy metals", or one metal | The sum of the four metals, or the four values |
| On what basis? | Not stated | A test report with its method, or a calculation from the formulation |
| When? | Often undated | The date of the test or of the statement |
| Which material version? | Not stated | The grade, batch or specification covered |
| Who answers for it? | A letterhead | A named issuer and signatory, and the laboratory where a test was made |
Article 5(4) does not say in what form a result is reported. A statement without exact values can therefore still be evidence if it answers the questions in the table. A measured value still helps: 12 mg/kg and 95 mg/kg both read "< 100", and only the value shows the margin left if the Commission lowers the limit under Article 5(7).
What Should You Ask Your Supplier For?
Ask per component, not per company or product family. For each component, name the material and ask for the sum of the four metals or the four values, the basis of the result, its date, and the grade, batch or specification covered. Under Article 16(1), suppliers provide the manufacturer with the information and documentation needed to demonstrate conformity.
- The component. Name the closure, label, liner or handle and its material as you buy it. One statement may cover several components if it lists each of them.
- The sum or the four values. Ask for the sum of the four metals, or the four values. Where a metal is reported below a reporting limit, ask how that value was counted.
- The basis. A test report names its method and its laboratory; a calculation names its formulation inputs. Article 35 speaks of tests, measurements and calculations alike.
- The date and the material version. Ask for the date and the grade, batch or specification covered. A new pigment, recycled input or plant then calls for a new statement.
- A change notice. Ask to be warned before a formulation or a source changes. Under Article 15(4), the manufacturer takes changes in packaging design or characteristics into account and re-assesses conformity where it could be affected.
Article 16(1) asks for one or more languages which can be easily understood by the manufacturer, so a statement in German suits a team that reads German. Under Article 15(10), a national authority receives the documentation, on reasoned request, in a language it can easily understand, within 10 days of receipt of the request. A German statement that a French or an Italian authority may ask for is best translated in advance. For converters, the five points describe a statement that a customer can file without further questions.
Does the Regulation Require a Laboratory Test for Every Component?
Not as such. Regulation (EU) 2025/40 names no test method for Article 5(4). Annex VII lists test reports among the elements of the technical documentation "wherever applicable". Article 35 requires tests, measurements and calculations to use reliable, accurate and reproducible methods that take into account the generally recognised state of the art and give results of low uncertainty.
Article 36(1) presumes that methods following harmonised standards whose references are published in the Official Journal meet Article 35. Article 36(2) adds a presumption where such methods are performed by conformity assessment bodies accredited under Regulation (EC) No 765/2008. This article names no standard and no laboratory, because the Regulation names none for Article 5(4).
The depth of evidence per component is argued in the file itself: Annex VII, point 2, requires an adequate analysis and assessment of the risks of non-conformity. In practice, coloured, printed or recycled-material components are the natural place for a test report.
Where Do Test Reports and Supplier Statements Live?
Test reports and supplier statements live in the technical documentation, drawn up by the manufacturer under Article 15(2) and Annex VII. Annex VII, point 2, lists the materials of components and test reports among its elements. Under Article 15(3), the manufacturer keeps that documentation with the declaration for 5 years, or 10 years for reusable packaging.
Annex VII, point 4, provides for a declaration of conformity for each packaging type, identifying the packaging it covers. Article 39(2) provides that the EU declaration of conformity has the model structure set out in Annex VIII, contains the elements specified in the module in Annex VII, and is continuously updated. A supplier statement therefore belongs to a packaging reference and its components, not to a supplier folder: one statement reused for every packaging that contains "some PP" supports none of them until checked. Our guides to the Annex VII technical documentation and to what a declaration of conformity covers describe both documents.
What Does the Referential Not Confirm?
Our dated PPWR referential (baseline reviewed 15 September 2026) confirms the four Key Facts, the statement that opens the section on the worst component, and Article 39(2) as quoted. Its claim check returned no match for the following statements, which are read on the linked text or are plain arithmetic, and are presented as such.
- The equivalence of 100 ppm by mass and 100 mg/kg, a unit conversion; the sum-not-per-metal sentence as worded here; and the arithmetic of the worked example.
- The without-prejudice clause of Article 5(4); Article 5(6) to 5(8); Article 71 as the source of the date; Article 70(3) and the two Decisions it keeps in force; recital 25; the adoption status of any delegated act under Article 5(7) or 5(8).
- Articles 15(2), 15(3), 15(4) and 15(10), Article 16(1), Article 18(2)(a), Articles 35 and 36, Annex VII, points 2 and 4, and the definitions of Article 3(1)(16), (43) and (44), as phrased here.
- Three readings: Article 5(4) fixes no form for a result; the Regulation names no test method for Article 5(4); no provision requires a laboratory test for every component.
Frequently Asked Questions
Is 100 ppm the same as 100 mg/kg?
Yes, when ppm is meant by mass. One part per million by mass is one milligram per kilogram, so "< 100 ppm" and the 100 mg/kg of Article 5(4) name the same number. If a statement does not say that its ppm is by mass, ask. Our referential does not vouch the conversion, which is arithmetic.
Is a supplier statement dated before 12 August 2026 still usable?
Often, if it still describes the component you buy. Recital 25 of Regulation (EU) 2025/40 speaks of maintaining the existing restrictions for the four metals. An older statement is therefore not void because of its date. Its weight depends on whether the grade, the pigment, the recycled input and the supplier are still the ones it describes.
How PPWR Connect Helps
PPWR Connect is software: it does not test packaging, and it is not a laboratory or a notified body. Substance lines, heavy metals included, are declared per packaging component as present, absent or not declared, each with its source and supplier evidence. A box left blank reads "not declared", never "no", and the declaration flows into the technical file. A supplier PDF such as a test report, a certificate or a datasheet is read by the platform and filed as evidence against the SKU for the Declaration of Conformity. Each recorded value keeps where it came from. To find the components that still rest on a bare "< 100 ppm", start with our PPWR compliance software or the PPWR readiness assessment.
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Rutherford (rutherford.fr) develops production control software for offset printers and converters, including ColorLoop. Veoria (veoria.com) develops inline colour measurement for label and packaging presses, including DeltaOne.