PPWR heavy metals limit: is a supplier's ‘below 100 ppm’ statement enough?

What exactly does the 100 ppm limit mean?

One ppm by mass equals one milligram per kilogram, so the PPWR ceiling is 100 mg/kg. The four restricted metals must be added together. A component containing 35 mg/kg lead, 20 mg/kg cadmium, 15 mg/kg mercury and 40 mg/kg hexavalent chromium reaches 110 mg/kg in total and therefore exceeds the limit.

The requirement applies to packaging and to any packaging component. A compliant outer carton cannot compensate for a non-compliant printed label, closure, liner, handle or pigment-rich decorative element. Each relevant component needs its own defensible assessment.

Which packaging is covered?

Article 2(1) gives PPWR a broad scope: it covers all packaging placed on the EU market, regardless of material and whether it is household, commercial or industrial packaging. Paper, plastics, metals, glass, wood, coatings, inks and adhesives can therefore all be relevant to the assessment.

Article 5(4) works alongside other legislation. Depending on the material and intended use, REACH restrictions and food-contact requirements may impose additional or stricter conditions. Passing the 100 ppm check is not a universal confirmation that the packaging is safe or legally compliant in every other respect.

Why a bare ‘below 100 ppm’ statement is weak

The statement repeats the legal conclusion but does not show how it was reached. It may not identify the packaging, the component, the material grade, the version, the production batch or even whether the result is the sum of all four metals.

Article 16 requires suppliers of packaging or packaging materials to provide the manufacturer with the information and documentation needed to demonstrate conformity. For the manufacturer, the practical question is not whether a PDF exists, but whether that PDF can be linked to the exact component used in the packaging being assessed.

What a useful supplier statement should contain

• The supplier's legal name and an attributable issuer
• An exact component, material, grade or specification reference
• A clear statement that the result concerns the combined concentration of Pb, Cd, Hg and Cr(VI), or separate results for all four
• The evidence basis: test report with method and laboratory, or a documented calculation based on formulation data
• The test, statement and specification dates, plus the relevant batch or version where applicable
• A commitment to notify you before changes to pigments, recycled feedstock, coatings, inks, suppliers or production processes
• A language that your team can understand and can make available to the relevant authority

Does every component need a laboratory test?

PPWR does not prescribe one heavy-metals laboratory test for every component. Annex VII instead requires an adequate analysis and assessment of the risks of non-conformity, while Article 35 expects measurements, calculations and tests to be reliable, accurate, reproducible and based on state-of-the-art methods.

That supports a risk-based approach. A recent accredited test tied to the exact material may be strong evidence. Formulation data and controlled supplier documentation may be proportionate for a stable, low-risk virgin material. A generic declaration is less persuasive for recycled inputs, intense pigments, printed elements, metal fittings or components with frequently changing sources.

Four practical scenarios

• A white virgin-plastic closure with a controlled formulation: supplier composition data and a representative test may support the assessment if the specification is locked.
• A brightly coloured recycled-plastic crate: variable feedstock and pigments increase uncertainty, so targeted testing and tighter change controls are prudent.
• A printed paper label: assess the paper, inks, coatings and adhesives rather than relying only on the paper mill's declaration.
• A private-label product imported from outside the EU: the EU importer must verify that the manufacturer prepared the required conformity documentation; a generic factory letter does not complete that check.

Exceptions that need separate review

PPWR preserves existing derogation decisions for certain glass packaging and certain plastic crates and pallets until they are amended or repealed. These are conditional regimes, not broad exemptions for all recycled glass or transport packaging.

The Commission may also lower the concentration limit or amend the existing derogations by delegated acts. Companies using these materials should verify the current legal status rather than relying on an old supplier template.

Who carries the final responsibility?

The supplier provides evidence, but the manufacturer carries out the conformity assessment under Article 38, prepares the Annex VII technical documentation and draws up the EU Declaration of Conformity under Article 39 and Annex VIII. In private-label models, the brand owner may itself be the manufacturer for PPWR purposes.

Importers must verify that the manufacturer has performed the conformity assessment and prepared the documentation. For single-use packaging, the manufacturer generally retains the technical documentation and declaration for five years; for reusable packaging, the period is ten years.

Checklist before 12 August 2026

• Break every packaging reference into components, including labels, closures, liners, coatings, inks and adhesives
• Assign each component to a supplier, material specification and current version
• Collect evidence that addresses the sum of all four restricted metals
• Rank components by risk and close evidence gaps with targeted testing
• Add supplier change-notification clauses and define when re-assessment is mandatory
• Store statements and reports against the exact component and packaging reference
• Review special materials for derogations and additional REACH or food-contact requirements

How EPRPilot helps

EPRPilot links components, material specifications, suppliers, test reports and declarations to the relevant packaging and SKU. Your team can see which evidence is current, which component still has a gap and whether a supplier change requires a new assessment.

The same controlled packaging record can support PPWR technical documentation and country-level EPR reporting. Instead of keeping heavy-metals statements in an email folder disconnected from the product, you maintain a traceable evidence chain in one place.