Testing & verification

Most requirements end in a lab report.

Knowing the rule is not evidence. These are the methods authorities and customers ask for, the standards behind them, and what each one actually proves.

6 method families · mapped to the articles they satisfy

Live obligation: Art. 5(5) PFAS
Typical lead time: 2 – 4 weeks
Methods listed: 6
Standards cited: 5
Last reviewed: 2026-08-16

Laboratory technician preparing a flexible packaging sample in a vial for analytical screening — Laboratory photography — sample preparation for total fluorine screening. Instrument detail, cool light, shallow depth of field.

Why this page exists

A market surveillance request does not accept a supplier’s word.

Most of PPWR resolves, eventually, into a document you either have or do not have. For substances of concern and recycled content that document is a test report; for recyclability it is an assessment; for minimisation and empty space it is a calculation you can reproduce.

This page maps each obligation to the evidence that satisfies it, so you can commission the right test once rather than the wrong test twice.

The one that is already live

PFAS limits on food-contact packaging have applied since 12 August 2026. If you place grease-resistant paper or board in food contact on the EU market and hold no fluorine data, that is a live exposure, not a 2030 problem.

Method register

What to test, and what it proves.

Each method is listed against the article it satisfies. Lead times are indicative and depend on sample preparation, not on the instrument.

PFAS in food-contact packagingTotal fluorine, then targeted LC-MS/MS That the pack is under 25 ppb for any single PFAS, 250 ppb for the sum, and 50 ppm total fluorine. Screening first, targeted analysis only if fluorine is found. Art. 5(5) 2–3 weeks

Heavy metalsPb, Cd, Hg, Cr(VI) That the four regulated metals stay under the 100 ppm combined limit. Usually a pigment or ink question rather than a substrate one. Art. 5(2) 1–2 weeks

Recycled content verificationChain of custody + analytical confirmation That the PCR percentage you claim is real and traceable. Audit evidence carries the claim; analysis backs it where the claim is material. EN 15343 3–6 weeks

Material identificationFTIR / NIR, layer analysis What the pack is actually made of, layer by layer. The first test to run on any laminate, because the datasheet and the reality often differ. FTIR · DSC 3–5 days

Recyclability assessmentDesign-for-recycling scoring, sortability trials Where the pack sits on the A/B/C scale. Provisional until the delegated act lands, but the structural findings will not change. Art. 6 4–8 weeks

CompostabilityIndustrial composting Only relevant where compostable packaging is permitted or required under Article 9. Not a general alternative to recyclability. EN 13432 12+ weeks

Lead times are indicative Sample preparation usually dominates, not instrument time

Start from the obligation

Which test does each requirement need?

Not every requirement ends in a lab. Three of the eight are satisfied by calculation and documentation alone — which is cheaper, and just as auditable.

Requirement	Evidence type	Method	Live today
Art. 5 — PFAS & metals	Lab report	Total fluorine + targeted LC-MS/MS; ICP for metals	● yes
Art. 6 — Recyclability	Assessment	Design-for-recycling scoring, sortability trial	◐ provisional
Art. 7 — Recycled content	Audit + analysis	Chain of custody per EN 15343	◐ method act pending
Art. 10 — Minimisation	Written justification	Annex IV criteria, dimensional data	● yes
Art. 24 — Empty space	Calculation	Volume ratio per pack configuration	— from 2030
Art. 12 — Labelling	Artwork conformity	Composition data + digital carrier check	— from 2028

● Obligation live now ◐ Testable, criteria not final — Future date

What each article demandsRequirements Find out which apply to youTools

Next step

Not sure which test you need?

Run the specification through the checker first. It tells you which obligations apply, and only then which of them actually require a lab.

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