Chemical Analysis for Packaging Materials under PPWR Requirements (for Toys & Hardgoods Products)
Based on Regulation (EU) 2025/40, our experts ensure that your packaging materials for Toys, Children's Products, Gifts & Premiums, Food Contact Materials (FCM), and other Hardgoods products comply with the European Union's requirements under Article 5: Substances of Concern of the Packaging and Packaging Waste Regulation (PPWR).
For brand owners, manufacturers, and retailers in the toys and hardgoods sector, the European Union's Packaging and Packaging Waste Regulation (PPWR) changes everything. Moving far beyond voluntary green initiatives, the PPWR introduces legally binding mandates that directly impact how toys, games, electronics, and durable goods are packaged, shipped, and sold across the EU.
The regulation introduces rigorous requirements across the entire packaging lifecycle, presenting unique challenges—and strategic opportunities—for consumer goods. Starting on August 12th, 2026, under Article 5: Substances of Concern, packaging must comply with updated chemical thresholds.
One of these strict limits is on the heavy metal content, which has been reduced to a total of less than 100 mg/kg for Lead (Pb), Cadmium (Cd), Mercury (Hg), and Hexavalent Chromium (Cr(VI)).
How can SGS help?
Meeting these strict limits requires absolute precision and verified data. Our comprehensive analytical testing solutions for such heavy metals help you minimize the risk of non-compliance with Article 5 under the Packaging and Packaging Waste Regulation (PPWR) legislation.
| Test Package | Test Item | Directive / Test Method | Sample Size Required | Turnaround Time (Working Days) | Price Remarks |
| For General Packaging Material (Non-FCM) | Heavy Metals in Packaging Material (Lead, Cadmium, Chromium VI, Mercury) | Regulation (EU) 2025/40 (with reference to CR 13695-1/2000) | 5 grams | 7 Working Days | Per color per material |
| For Food Contact Packaging Material | Heavy Metals in packaging material (Lead, Cadmium, Chromium VI, Mercury) | Regulation (EU) 2025/40 (with reference to CR 13695-1/2000) | 5 grams | 7 Working Days | |
| 140 PFAS in food packaging material | Regulation (EU) 2025/40 / In-House method, by GC/MS and LC-MS/MS | 5 grams | 7 Working Days | ||
| Total Fluorine | Regulation (EU) 2025/40 (with reference to EN 14582:2016) | 2 grams | 7 Working Days |
* Note: Orders exceeding 5 colors/materials require direct consultation with our team for custom arrangements.
Q: What does Article 5 of the PPWR actually regulate?
A: Article 5 focuses on substances of concern in packaging. It mandates that packaging must be manufactured to minimize the presence and concentration of hazardous substances. Specifically, it maintains long-standing restrictions on heavy metals and introduces strict, legally binding limits for per- and polyfluoroalkyl substances (PFAS), particularly in food-contact packaging.
Q: What are the specific heavy metal limits under Article 5?
A: The regulation preserves the cumulative limit threshold established by prior EU directives. The total combined concentration of lead, cadmium, mercury, and hexavalent chromium present in any packaging or packaging component must not exceed 100 mg/kg.
Q: Who within the supply chain carries the legal responsibility for compliance?
A: The primary legal responsibility falls on the manufacturer, importer, or brand owner who places the packaged product on the EU market for the first time. While testing obligations are not explicitly mapped step-by-step in the text, the economic operator introducing the packaging is fully accountable for ensuring it meets all limit values and must maintain supporting technical documentation.
Q: Are there any exemptions or phase-in periods for existing packaging stocks?
A: There are no general volume thresholds, de minimis exemptions, or grace periods for existing inventory. Once the rules take effect, any non-compliant packaging placed on the market violates the regulation. However, food-contact packaging that was already lawfully placed on the market before the enforcement date does not retroactively need to be recalled from store shelves.
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