Substances (Art. 5)
Overview
Substances (Art. 5) is the fourth step of a packaging item's journey. It covers the regulation's substance requirements for the item: minimising substances of concern, the heavy-metals limit, and, for food-contact packaging, the PFAS limits. The step reads the evidence you filed under Supplier information, mirrored read-only, and the item's substance state is what the Packaging list shows in its Substances column as Conform or Open.
What the step evaluates
| Requirement | What it means | Basis |
|---|---|---|
| Substances of concern | Packaging is manufactured so that the presence and concentration of substances of concern are minimised. | Art. 5(1) |
| Heavy metals | The sum of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg. | Art. 5(4) |
| PFAS in food-contact packaging | PFAS limits of 25/250 ppb for targeted measurements and 50 ppm for total fluorine apply to food-contact packaging. | Art. 5(5) |
Which requirements apply follows the item's classification: the PFAS limits only bind items whose classification says food contact, which is also why the PFAS test documentation slot in Supplier information shows n/a for other items.
Where the evidence comes from
The substance evidence lives in Supplier information and is mirrored here read-only:
- Substance compliance declaration (Art. 5(4)/(6)), the component-level evidence for the limits.
- Fluorine / PFAS test documentation (Art. 5(5)(c)), for food-contact items.
If something is missing or wrong, fix it in Supplier information; this step reflects the change immediately.
The substance state
- Conform. The filed evidence supports the applicable limits.
- Open. Evidence is missing or does not yet support conformity, and the gap keeps the item's compliance status at Partial or Open.
Tips
- Request substance declarations that state the measured values or explicit conformity with Art. 5(4), not just "complies with EU law".
- For food-contact items, make sure the PFAS documentation covers the actual material in the actual item.
ℹ️ Regulatory context. The substance regime is Article 5 of the regulation: minimisation (5(1)), the heavy-metals sum limit (5(4)), the PFAS limits for food-contact packaging (5(5)), and the related evidence duties (5(6), 5(5)(c)). See Regulation (EU) 2025/40.