PPWR Series: Substances of Concern
Substances of Concern in Packaging: Why You Need to Pay Attention
The EU’s Green Deal is transforming the EU legislative framework in the field of sustainability, reshaping policies to protect both people and the planet and tackling harmful substances by pushing for packaging and materials that are safer, more circular, and fully recyclable. Legislation such as the Packaging and Packaging Waste Regulation (PPWR) and the Ecodesign for Sustainable Products Regulation(ESPR) introduce the concept of ‘Substances of Concern’ (SoC).
Substances of Concern
Under the ESPR, SoC are defined as:
SVHC under EU REACH
specific hazard categories under the CLP Regulation (e.g. CMR, PBT, vPvB, STOT)
'POP' substances
A substance that negatively impacts reuse or recycling (further detail by The EU Commission by Sept 2026)
The presence of SoC should be minimised or substituted so that they do not adversely affect human health or the environment.
Specific Requirements under PPWR
The PPWR contains a number of provisions relating to SoC in packaging:
Packaging should be manufactured to minimise the presence and concentration of substances of concern, considering their impact on human health and the environment throughout its life cycle (by Aug 2026).
The sum of concentrations of lead, cadmium, mercury, and hexavalent chromium in packaging or components should not exceed 100 mg/kg (re-iteration of existing requirement).
Food-contact packaging containing PFAS above specific concentrations is restricted.
The European Commission will monitor and assess the presence of substances of concern in packaging and may take relevant follow-up measures, including new restrictions or additions to design for recycling criteria.
Whilst minimisation and substitution are the primary goal, it may not always be possible to completely eradicate all SoC from all packaging. In instances where SVCHs remain present, producers and importers may need to notify ECHA about the use/presence and under the REACH Regulation, will need to inform their supply chain of the presence where concentration is above 0.1% weight by weight (w/w). Should consumers request information, companies must provide details within 45 days to allow safe use of the article including, as a minimum, the name of that substance. [Existing requirements]. Packaging containing substances of concern will also have to be marked using standardised, open, digital technologies in the future as part of the digital product passport and transparency principles.
Bloom Regulatory is partnering with companies to uncover and address potential Substances of Concern in their packaging and raw materials; helping them stay ahead by identifying opportunities for minimisation and substitution. If you're considering a similar initiative, we’d love to explore how we can support your journey. Get in touch to learn more.
Amanda Isom