Heavy Metals in Packaging: The 100 mg/kg Sum Limit

The sum of the concentration levels of lead, cadmium, mercury and hexavalent chromium present in packaging or in any of its components must not exceed 100 milligrams per kilogram by weight. The four metals are added together, not judged separately: a component carrying 60 mg/kg of lead and 50 of cadmium fails, although each metal alone looks modest. The limit is the directive era's oldest packaging rule, carried into Article 5 essentially unchanged, and it is a total-content limit - what is in the material, not what migrates out of it.

Its age does not make it historical. Market surveillance still finds it - in pigments, in recycled streams, in imported decorated goods - precisely because supply chains stopped looking for it.

Lead: pigments and stabilisers in older plastic formulations, ceramic-style decorations, recycled glass where cullet streams carried leaded glass, soldered or sealed elements. Cadmium: bright pigments - the classic reds and yellows - in plastics and prints, now largely substituted in reputable supply and still present in low-cost imported decoration. Mercury: rarely intentional in packaging, appearing as a contaminant in recycled or industrial inputs. Hexavalent chromium: leather elements in premium packaging, chromate pigments and corrosion-protection treatments on metal components. The pattern across all four: decoration and recycled content are the two doors, and both are supplier-evidence questions before they are laboratory questions.

Screening is by X-ray fluorescence (XRF), which reads the metals' presence quickly and non-destructively and is the right first pass across a range; positive or borderline screens resolve to laboratory determination by digestion and spectrometry, reported per metal so the sum can be formed. Two disciplines matter. Component separation: test components separately where they differ materially - a compliant board cannot dilute a non-compliant ink to compliance, because the limit applies to the component as well as the whole. And basis discipline: results must be on the material's weight as placed, not on an extract or a migration simulant - the food-contact migration regime is a different legal animal, and reports written for it do not answer this limit.

The directive era produced derogations under which certain recycled glasses could exceed the limit, because leaded cullet in the stream made strict compliance impracticable while the alternative - landfilling the stream - was worse. The regulation's framework continues to treat defined cases through its derogation machinery rather than by ignoring the limit. The hygiene lesson generalises beyond glass: a derogation is a published, scoped, dated instrument. If a supplier's position is 'we are allowed to exceed', the file needs the instrument's identity and the scope that covers this material - not the sentence. Businesses inheriting legacy derogation positions from the directive years should re-verify them against the regulation's current text as part of the citation sweep the timeline station prescribed.

Surveillance findings on the metals sum cluster in one commercial pattern: decorated goods - printed, metallised, ceramic-styled - imported from supply chains where pigment substitution has not happened and declarations are boilerplate. The importer's verification duty meets the pattern head-on: XRF screening of incoming decorated lines is cheap, fast and decisive, and its results belong in the verification file rather than in a quality drawer. Domestic and intra-EU supply is not exempt from the pattern - recycled content and legacy print stocks reproduce it - but its centre of gravity is the long, declaration-thin supply chain, which is why this limit, of all the station's duties, most rewards the testing-your-own-goods habit over the trusting-the-paper habit.

Newer duties will dominate the headlines of the regulation's first years, and the metals limit will continue to be found, quietly, in surveillance reports - because it is the duty most likely to be delegated entirely to supplier paper, in chains where the paper is weakest. Its lesson is the station's in miniature: a limit that everyone assumes someone else is checking is a limit checked by nobody. One XRF session a year across the decorated and recycled lines is the entire cost of not being that finding. Few duties in the regulation offer so much safety for so little money.