Regulation (EU) 2025/40Applies from 12 Aug 2026Independent publication - not legal advice
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Station 07: Substances and PFAS

Article 5: minimising substances of concern, the PFAS thresholds in food-contact packaging and the heavy-metals ceiling.

The station guide

Station guide Substances of Concern and PFAS Under the PPWR: Article 5 Explained Minimise substances of concern, hold PFAS in food-contact packaging under the ppb thresholds, keep the heavy-metals sum under 100 mg/kg. The pillar guide to the regulation's chemistry bench.

Working guides in this station

Substances and PFAS Heavy Metals in Packaging: The 100 mg/kg Sum Limit Lead, cadmium, mercury and hexavalent chromium: summed, in packaging or any component, at no more than 100 mg/kg. The oldest duty in the regulation - its sources, its testing, and the derogation history to know. Substances and PFAS Inks, Adhesives and Coatings: Where Substances of Concern Hide The substrate is rarely the problem. The colour, the glue line and the functional coating carry the pigments, plasticisers, photoinitiators and PFAS. A hiding-place tour for specification reviews. Substances and PFAS Legacy Substances in Recycled Materials: The Circular Economy's Chemistry Problem Recycling inherits the chemistry of the past: brominated flame retardants, legacy plasticisers, mineral oils, PFAS in recycled streams. How Article 5's duties meet Article 7's targets without either being sacrificed. Substances and PFAS PFAS in Food-Contact Packaging: The 25 / 250 / 50 Thresholds From 12 August 2026, food-contact packaging at or above the PFAS thresholds may not be placed on the market. What the three numbers measure, how total fluorine screening works, and what evidence a line needs. Substances and PFAS PFAS in Paper and Board: Greaseproofing, Moulded Fibre and the Alternatives Paper's PFAS problem is one application - grease resistance - in wraps, bags, moulded fibre and fast-food board. Where it was used, how to detect it, and the alternative technologies that replaced it in the markets that banned it first. Substances and PFAS Substance Information and Digital Disclosure: Who Gets Told What From safety data down the chain to data carriers on the pack: the information duties around substances of concern - what manufacturers must hold, communicate and increasingly publish digitally. Substances and PFAS Substances of Concern: What the Term Covers and What Minimisation Requires The PPWR borrows its concern list from the chemicals framework - CMRs, endocrine disruptors, persistent substances and more. How the category is built, and what a defensible minimisation file looks like. Substances and PFAS Substitution in Practice: Replacing a Substance Without Regretting It The method that avoids regrettable substitution: define the function, screen candidates against hazard, test performance in the real application, document the decision. With the packaging functions where substitution is most active. Substances and PFAS Supplier Declarations for Substances: Asking So the Answer Is Evidence The declaration letter that actually works: named thresholds, intentional-use statements, basis of knowledge, change notification. Plus how to grade the answers that come back. Substances and PFAS Testing Packaging for PFAS and Heavy Metals: A Practical Programme Total fluorine screening, targeted PFAS analysis, XRF for metals and the laboratory methods behind them. Designing a testing programme by risk - what to test, how often, and how to file results. Substances and PFAS The PPWR and the Universal PFAS Restriction: Two Regimes, One Direction Beyond packaging, a universal PFAS restriction is moving through ECHA that would phase the whole family out across applications, with derogations. How it interacts with Article 5 - and why packaging businesses should plan on the wider map.