PPWR heavy metal limits

Article 5(4) caps lead, cadmium, mercury and hexavalent chromium at 100 mg/kg — combined, not four separate ceilings. A packaging can pass on each metal individually and still fail the sum.

The limit reaches all packaging, not only food contact, and it has applied since 12 August 2026. In practice the gap is rarely the limit itself but the evidence: a supplier statement without a test report supports a conditional verdict with the assumption written down, and not a compliant one. That distinction is the first thing an inspector tends to probe, so the platform keeps it visible rather than rounding it up.