Analyses required under the PPWR

General informations

Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), which entered into force on 11 February 2025, applies from 12 August 2026.
Its aim is to prevent unnecessary packaging and promote reuse, refilling and recycling; to harmonise national measures in order to avoid barriers to trade and distortions of competition; and to contribute to the circular economy and climate neutrality by 2050.
Article 5 sets out requirements for substances present in packaging, in particular heavy metals and per- and polyfluoroalkyl substances (PFAS).
Despite a guidance document published by the European Commission, it is not always straightforward to select the appropriate analytical methods. The CTP’s expertise enables you to anticipate and meet these new requirements thanks to its chemical analysis laboratory, accredited by COFRAC Essais under number 1-0552 (scope available at www.cofrac.fr).

 
Technical Data and Achievements

Article 5 of the PPWR introduces new regulatory limits and requires specific analytical methods.
See the ‘European PPWR Regulation’ Expertise Sheet for a better understanding of the overall context of this regulation.

Restrictions on heavy metals
The sum of the concentrations of lead, cadmium, mercury and hexavalent chromium must not exceed 100 mg/kg of packaging. This restriction has been carried over unchanged from Directive 94/62/EC, which has now been repealed.

Methods for analysing heavy metals
The CTP offers heavy metal testing to assess compliance with this restriction, using the following method:

• Microwave digestion of the sample using of a mixture of acids,
  
• Determination of cadmium, chromium, lead and mercury by ICP emission spectroscopy (plasma torch)..

Restrictions on PFAS
Under Article 5 of the PPWR, packaging placed on the market must comply with the following limits:

• 25 ppb for any PFAS measured by targeted analysis (excluding polymeric PFAS),
• 250 ppb for the sum of PFAS measured as the sum of targeted PFAS analysed,
• 50 ppm for PFAS (including polymeric PFAS).

Methods for analysing PFAS
The CTP is actively involved in drafting the European CEN standard for the determination of TF (Total Fluorine) and TOF (Total Organic Fluorine) in paper and board: inter-laboratory tests have been carried out and publication is expected in the first half of 2027. The aim is to provide a harmonised basis for assessing compliance with the PPWR’s 50 ppm criterion for the paper and board sector.
Several methods for targeted PFAS analysis are currently under discussion. The CTP is also working to standardise a method for targeted PFAS analysis and can assist you in selecting the most appropriate method.

Heavy metal analysis		Fluorine analysis