PPWR Heavy Metals: The 100 mg/kg Limit and Desiccant Sachets

A specification that used to sit quietly in the background is now being checked at the supplier level. Since 12 August 2026 the EU packaging regulation makes the long-standing heavy-metal limit enforceable — and buyers assembling a compliance file are asking their desiccant supplier to document it. Here is exactly what the rule says, and what a compliant test report looks like.

What Article 5(4) Actually Says

Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation, or PPWR — Article 5(4):

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.

Three things follow from that sentence:

• It is a sum, not four separate limits. You cannot pass by keeping each metal individually low if the total still exceeds 100 mg/kg.
• It applies to packaging and packaging components — not just to the finished box or bottle.
• The unit is mg/kg, which is the same as ppm by weight. The two expressions are used interchangeably in buyer specifications.

What It Covers, and What Changed in August 2026

The number is not new. A 100 mg/kg combined limit for these same four metals has applied to packaging in the EU for years under Directive 94/62/EC, which the PPWR repeals and replaces. What changed is the framework around it.

From 12 August 2026, under the new regulation:

• The heavy-metal limit becomes enforceable under the PPWR itself. A buyer who previously had no obvious place to point at can now cite Article 5(4) directly.
• It applies to all packaging, not only food-contact packaging. This is the point most often misread.
• PFAS limits for food-contact packaging also take effect — 25 ppb for any single targeted PFAS, 250 ppb for the sum of targeted PFAS, and 50 ppm for total PFAS including polymeric PFAS.
• Conformity must be documented. Manufacturers are expected to draw up technical documentation under Annex VII and keep it for five years for single-use packaging or ten years for reusable packaging.

That last point is why this has moved from a laboratory question to a purchasing question. The obligation is not only to comply — it is to be able to show that you comply, for years afterwards.

Where Desiccant Sachets Fit

Whether a desiccant sachet is itself treated as packaging depends on how it is placed on the market and on the definition applied — that is a question for your own regulatory adviser, and we do not pretend to settle it here.

What is not in doubt is the commercial reality. A desiccant sachet travels inside the packaging a buyer is declaring. When that buyer assembles a technical file under Annex VII, the sachet is part of what they are putting on the EU market. So they ask their desiccant supplier for heavy-metal documentation — not because a rule names sachets specifically, but because they need to be able to stand behind the whole packaging system.

If you are being asked for that documentation, you are not being asked something unusual. You are being asked for evidence.

How Compliance Is Demonstrated

The established route is laboratory testing of the material against the four metals, then holding the report. In practice a usable heavy-metal report states:

• Each metal reported individually — lead, cadmium, mercury and hexavalent chromium, not a single pass or fail line.
• The result for each — a measured value, or an explicit statement that it was below the limit of detection.
• The limit of detection for each metal. This is the part buyers should look for and suppliers most often omit. A statement that a metal was not detected means only that it fell below the laboratory's detection threshold — so the threshold is what tells you how much confidence the result carries. A detection limit of 50 mg/kg would be a very weak result against a 100 mg/kg ceiling.
• The method used. Heavy-metal testing for packaging is commonly run under CEN CR 13895-1:2000, with quantification by ICP-OES, AAS or UV-Vis.
• The material actually tested — described specifically enough that you can tell it is the item you are buying.
• The laboratory and the date.

What Our Test Shows

Our clay desiccant sachets have been tested against PPWR Article 5(4) by SGS. All four metals — cadmium, lead, mercury and hexavalent chromium — were reported below the limit of detection.

The report is SZXEC26005243502, issued 16 September 2026. Buyers who need it for their own Annex VII file can request the full document from us; we will send it as issued rather than as a summary.

What to Ask Your Desiccant Supplier

Whether you buy from us or from anyone else, these five questions separate a real report from a reassuring sentence:

• Does the report name all four metals individually, with a result for each?
• Does it state the limit of detection for each metal?
• Does it name the specific material tested, or only say "desiccant"?
• Is it from an accredited laboratory, and is it dated?
• Does it reference the article you actually have to comply with — PPWR Article 5(4) — rather than an older directive?

Frequently Asked Questions

Is the 100 mg/kg limit new?

The number is not new. The same 100 mg/kg combined limit for lead, cadmium, mercury and hexavalent chromium has applied under Directive 94/62/EC, which the PPWR replaces. What is new is that it is now enforceable under Regulation (EU) 2025/40 from 12 August 2026, with technical documentation required under Annex VII.

Does it apply to non-food packaging?

Yes. The heavy-metal limit in Article 5(4) applies to packaging generally, not only to food-contact packaging. The PFAS restrictions introduced at the same time are the ones limited to food-contact packaging.

What does "not detected" actually mean?

It means the concentration was below the laboratory's limit of detection for that metal, not that the metal is absent. Always ask what that limit is — a detection limit far below 100 mg/kg gives you a strong result, while one close to it gives you very little.

How long must the documentation be kept?

Under the PPWR, technical documentation drawn up under Annex VII is to be kept for five years for single-use packaging and ten years for reusable packaging.

Do desiccant sachets need to be tested?

Whether a sachet is itself in scope depends on the definition and on how it is placed on the market, so treat that as a question for your regulatory adviser. The practical driver is that the sachet travels inside packaging you are declaring, so buyers ask for the evidence as part of their own file. Having the report is what lets you answer.

If you need our PPWR test report for your compliance file, tell us the market and the end use and we will send the document with the specification.