Keep the sum of lead, cadmium, mercury and hexavalent chromium in packaging or packaging components at or below 100 mg/kg.

Manufacturers and importers of packaging must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

It is Art. 5(4), in the Packaging and Packaging Waste Regulation. as of 2026-08-18
The act gives its timing as: From 12 August 2026 (Art. 71). as of 2026-08-18
It names 5 industries by name: Plastics converting, Paper and board, Glass, Aluminium and Wood. as of 2026-08-18
Compliance is checked by technical documentation (Annex VII), continuous. as of 2026-08-18

Addressee Manufacturers and importers of packagingAct Regulation (EU) 2025/40, base actArticle Art. 5(4)Class Businesses

What changes

THE LEVEL DOES NOT MOVE. 100 ppm and 100 mg/kg are the same concentration, and the limit has bound since 2001 under 94/62/EC Art. 11(1). Reading this row as a new restriction would be wrong. What does move is the exemption regime, which is SUB-03.

Prior rule vs new rule

Prior rule

Trigger

packaging or packaging components placed on the market

Obligation

Sum of lead, cadmium, mercury and hexavalent chromium not to exceed 100 ppm by weight, five years from the date in Art. 22(1) of the Directive.

New rule

Trigger

packaging or a packaging component placed on the market

Obligation

Sum of lead, cadmium, mercury and hexavalent chromium not to exceed 100 mg/kg.

Who is affected

Addressee

Manufacturers and importers of packaging

Class

Businesses

Sectors

Names Plastics converting, Paper and board, Glass and ceramics, Aluminium and metals, Wood and wood products · Reaches Waste and landfill, Chemicals and refining

Applies

From 12 August 2026 (Art. 71)

Burden drivers

D1 · D4 — 2 of 7 marks fire on this provision.

No size threshold.

Source text

Verbatim

the sum of the concentrations of lead, cadmium, mercury and hexavalent chromium resulting from substances present in packaging or packaging components shall not exceed 100 mg/kg.

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