Substances of Concern and PFAS Under the PPWR: Article 5 Explained

Article 5 is the regulation's chemistry rule, and it applies from the first day - 12 August 2026 - not in the 2030 wave. It has three working parts. A general duty: the presence of substances of concern in packaging and its components must be minimised. A specific prohibition family: PFAS - per- and polyfluoroalkyl substances - in food-contact packaging may not be placed on the market at or above threshold values of 25 ppb for any individual PFAS, 250 ppb for the sum of PFAS excluding polymeric PFAS, and 50 ppm for PFAS including polymeric PFAS, where total fluorine above 50 ppm must be evidenced as not coming from PFAS. And a carried-over ceiling: the sum of lead, cadmium, mercury and hexavalent chromium in packaging or its components may not exceed 100 mg/kg by weight.

Everything in this station is the working-out of those three parts: what the terms mean, how the testing is done, where the substances hide in real packs, and how the duties interact with the wider chemical-law landscape - REACH, the food-contact framework, and the universal PFAS restriction now moving through ECHA.

The general duty is deliberately not a ban list. Substances of concern - broadly, substances meeting the hazard criteria the article references from the chemicals framework, including carcinogens, mutagens, reproductive toxicants, endocrine disruptors and persistent substances - must be minimised in packaging as far as the design allows. In practice the duty is discharged as a documented process: know what is in your packaging (the supplier evidence discipline), prefer the alternative with the lower concern profile where performance allows, and be able to show the reasoning. It resembles the substitution logic of chemicals law more than the threshold logic of the PFAS rules, and authorities will read it that way: the file, not a number, is the evidence.

The desk's working interpretation, stated as interpretation: a manufacturer who cannot list the substances of concern present in its own packaging has not begun to minimise them.

The PFAS thresholds come first, because they are the sharpest duty and the one with a date already past - testing method, scope and the total-fluorine screening logic included. Then the metals ceiling, the oldest duty in the regulation and still a live finding. Then the craft layer: testing practice, supplier declarations, and the hiding places - inks, adhesives, coatings and greaseproof papers. Then the two systemic questions: legacy substances riding in on recycled feedstock, and the coming universal PFAS restriction that will redraw this whole area. Substitution practice and digital disclosure close the station. Food-contact readers should keep the neighbouring framework in view throughout: Article 5 sits alongside the food-contact regime, it does not absorb it.

Three moves open any Article 5 programme, in this order. Classify the range by contact: which lines are food-contact (the PFAS thresholds' population), which carry decoration or recycled content (the metals' usual doors), which are plain (the minimisation inventory still applies). Commission the screens: total fluorine across food-contact materials, XRF across components - one laboratory round that converts the whole station from theory into a findings list. And issue the declaration requests in the form this station prescribes, so the evidence arrives while the screens are running. A programme that has done these three things by the end of its first quarter has a findings list, a supplier map and a laboratory baseline - everything else in the station is working those three artefacts down.

The chemistry bench has one rule that summarises the station: no invisible chemistry. Every substance family in every line should be visible in an inventory, priced by a threshold or a minimisation decision, and evidenced by a declaration or a test. Visibility is achievable for every business in this regulation's scope, at a cost proportionate to its range - which is precisely why authorities will treat invisibility as a choice rather than a misfortune. Make the other choice, on paper, from the first quarter of the programme.