A heavy metals test report arrives with a purchase order, everyone reads the word “pass”, and the file is closed. In a meaningful share of cases, that report does not answer the question the buyer believes it answers — because there are two entirely different heavy metals tests, run under two different bodies of law, and suppliers tend to send whichever one they happen to hold.
One measures what is present in the packaging material. The other measures what actually transfers into the food. A clean result on the first says nothing about the second. This guide explains what each test proves, which rule each sits under, and how to read a supplier’s report closely enough to know what you have actually been given.
Which Heavy Metals Are Regulated in Packaging
Four metals carry the specific restriction that applies to packaging placed on the EU market: lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium, written Cr(VI).
Under Article 5 of the Packaging and Packaging Waste Regulation — Regulation (EU) 2025/40 — the sum of the concentrations of these four metals in packaging, or in any packaging component, must not exceed 100 mg/kg. That is 100 parts per million by weight. The limit has applied since 12 August 2026, and it carried over from the earlier Packaging and Packaging Waste Directive rather than appearing for the first time under PPWR.
Two features of that limit are routinely misread. First, it is a combined figure: the four metals are added together, not assessed one by one against separate ceilings. Second, it applies to the packaging component, not to the finished item as an average. A printed sleeve, a molded lid and a fiber bowl are three components. A high reading on one is not diluted by two clean readings on the others.
Hexavalent chromium is the one most often left out of a supplier’s scope, and its absence is easy to miss because the report still says “heavy metals”. If a report covers Pb, Cd and Hg but not Cr(VI), it does not demonstrate compliance with the 100 mg/kg limit, whatever the summary line says.
Content Testing: What Is in the Material
Content testing answers a compositional question. A sample of the packaging material is digested — broken down completely, usually in acid — and the resulting solution is analyzed, typically by ICP-MS or ICP-OES, to quantify how much of each metal the material contains.
The result is expressed as a concentration in the material: milligrams of metal per kilogram of packaging. It is the figure the PPWR 100 mg/kg limit is written against.
What matters about this method is that it is deliberately indifferent to whether any of that metal could ever reach food. The sample is destroyed in order to measure everything present, including metal locked permanently inside a pigment particle or bound into the fiber structure. That is the intent. The PPWR restriction is a limit on what goes into circulation as packaging waste, not a food-safety limit — it exists so that heavy metals do not accumulate in compost, in recyclate and in landfill leachate.
So a content result tells you whether the material may legally be placed on the market as packaging. It does not tell you whether the packaging is safe for the food you intend to put in it.
Migration Testing: What Reaches the Food
Migration testing answers a completely different question: under realistic conditions of use, how much of each metal actually transfers out of the packaging and into what is inside it?
The packaging is filled with either the real food or a defined food simulant, held under specified conditions, and the liquid — not the packaging — is then analyzed. The result is expressed as a concentration in the food or simulant, usually mg/kg of food, and it sits under food-contact law rather than under PPWR: Regulation (EC) 1935/2004 as the framework, with the detailed simulant and condition rules drawn from Regulation (EU) 10/2011 and applied by analogy to non-plastic materials.
Because the metal must physically leave the material to be counted, a migration result is almost always far lower than the content result for the same item. This is the single most common source of confusion when the two reports are read side by side: the numbers do not agree, and they are not supposed to.
Why a Clean Content Report Is Not a Migration Result
The two tests are not different levels of rigour for the same question. They are different questions, and neither substitutes for the other.
A material can sit comfortably under 100 mg/kg on content and still release more than is acceptable into a hot, acidic food — if the metal present happens to be in a mobile, soluble form. A material can also carry a relatively high content figure while releasing almost nothing, because the metal is bound in a form that does not leach. Composition and behavior are related, but not reliably enough to infer one from the other.
This is why “we have heavy metals testing” is an incomplete answer from a supplier, and why the useful follow-up question is always: testing of what — the material, or what comes out of it?
| Content testing | Migration testing | |
|---|---|---|
| Question answered | What is in the material? | What transfers into the food? |
| What is analyzed | The packaging, digested | The food or food simulant |
| Legal basis | PPWR, Regulation (EU) 2025/40, Article 5 | Food-contact law, Regulation (EC) 1935/2004 |
| Limit | 100 mg/kg, four metals combined | Set per metal, per material and per use |
| Result expressed as | mg/kg of packaging | mg/kg of food or simulant |
| Purpose of the limit | Waste streams — compost, recyclate, leachate | Consumer safety |
| Sample survives? | No — destroyed to measure everything | Yes — only what leaves is measured |
Test Conditions Decide What a Migration Result Means
A migration figure without its conditions is not a result. It is a number.
Migration is driven by three variables, and every one of them is chosen before the test begins: what the packaging is filled with, how hot it is, and how long the contact lasts. Change any of them and the figure changes with it — often by an order of magnitude.
The simulant stands in for the food type. Distilled water represents neutral aqueous foods. Three per cent acetic acid represents acidic foods, and it is considerably more aggressive than water, because acid mobilises metals that plain water leaves in place. Ten per cent ethanol represents alcoholic and some dairy applications, and vegetable oil or a substitute represents fatty foods.
Time and temperature are then set to reflect the intended use. Two hours at 40 °C is a reasonable model for a cold drink. It is not a model for a 90 °C coffee held in the cup for twenty minutes, and it is not a model for a hot soup sitting in a sealed container through a forty-minute delivery.
The practical consequence for a buyer is direct. A migration report run on distilled water at 40 °C, presented as evidence for a hot coffee cup or a curry container, is being used outside the conditions it was produced under. The report is not wrong. It is simply answering a question about a different product.
Who carries the 100 mg/kg obligation?
The manufacturer of the packaging holds it. But if you buy unbranded stock and place it on the EU market under your own name, that obligation travels to you along with the goods — which is why private-label buyers need the report in their own file rather than a verbal assurance that one exists.
A test report is not a declaration
A report is lab data: what was measured, on one sample, on one day. A declaration is the manufacturer’s legal statement that the product meets applicable law, signed and carried by them. Buyers are routinely handed one and told it covers both. It does not, and the two are not interchangeable in an inspection.
The 50-second video covers the content and migration distinction before you read another supplier report.
How to Read a Heavy Metals Test Report
Five things determine whether a report is worth what the supplier is claiming for it. They can all be checked in a couple of minutes.
1. Scope — which item was tested
Find the sample description and match it against the product you are actually buying. A report on an unprinted white bowl does not cover the same bowl with four-color print, because the ink is a component in its own right and inks are a well-known source of heavy metals. A report on a 500 ml container does not automatically cover the 1,000 ml version if the two are molded from different pulp batches.
2. Metals — which four, or which three
Check that Pb, Cd, Hg and Cr(VI) all appear. Hexavalent chromium is the one that goes missing, and a three-metal report cannot demonstrate compliance with a four-metal limit.
3. Method — content or migration
Look for what was actually analyzed. Acid digestion followed by ICP-MS or ICP-OES indicates content testing. A named simulant with a stated time and temperature indicates migration testing. If the report gives a simulant, it is a migration report, whatever the covering email calls it.
4. Conditions — and whether they match your use
On a migration report, read the simulant, the temperature and the contact time, then compare them against how your product is genuinely used: hottest realistic fill, longest realistic hold, most aggressive food you serve in that format. If the conditions are milder than your reality, ask for a test at your conditions.
5. Laboratory and date
Check that the laboratory is accredited to ISO/IEC 17025 for the methods used, and check the date. A test report is a snapshot of one sample on one day. If the raw material supply, the ink system or the production site has changed since, the report describes a product that no longer exists in that form.
Where Heavy Metals Come From in Fiber-Based Packaging
Understanding the sources explains why the scope question in point one matters so much.
Inks, pigments and coatings are the most significant contributor in printed packaging. Some traditional pigments were built on heavy metal compounds, and while the worst have long been displaced in regulated markets, print is still the first place a competent assessment looks.
Recycled fiber carries whatever entered the stream ahead of it. That is not an argument against recycled content — it is the reason recycled-content packaging intended for food contact needs its own testing rather than inheriting a result from a virgin-fiber equivalent.
Agricultural residue and process water matter for bagasse and other residue-based fibers, where soil composition and mill water chemistry both leave a trace. Virgin wood pulp and sugarcane bagasse both typically sit far below the threshold, but “typically” is a statement about the material class, not about your consignment.
Adhesives and functional additives complete the picture. Any component added for a purpose — a seam adhesive, a barrier treatment, a release agent — is a component under Article 5 and counts toward the same limit.
What to Ask Your Supplier
Four questions, asked before the order rather than after the container has landed, resolve almost every ambiguity:
Which metals were tested, and does that include hexavalent chromium? The answer should be immediate and specific.
Is this a content report or a migration report? A supplier who does not distinguish the two has not read their own documentation.
What were the conditions, and do they match how we will use the product? Name your temperature, your hold time and your food type, and ask directly whether the report covers them.
Does the report cover the exact specification we are buying — the same print, the same size, the same material? If not, ask what it would take to have the actual specification tested.
Every serious manufacturer expects these questions and can answer them in a sentence each. A supplier who cannot is telling you something useful about the documentation behind the product, and the time to learn that is before the purchase order, not after a customer complaint.
Heavy Metals Documentation from Ekoroll
Ekoroll supplies paper cups, kraft food containers and molded sugarcane fiber packaging from İzmir, Turkey, and provides test documentation on a per-format basis rather than a single certificate covering the range.
That distinction is deliberate, and it follows directly from how Article 5 works. Because the limit applies per packaging component, a document that genuinely supports a compliance position has to identify the format, the print specification and the material it covers. A single blanket certificate applied to an entire catalogue does not do that, however impressive it looks attached to a quotation.
For any specific format, we can provide the relevant test reports along with the Declaration of Conformity for that product, and where your intended use falls outside the conditions of an existing report, we will say so rather than let a mismatched document travel with the order. For a wider view of what a compliance file should contain, see our guide to PPWR-compliant food packaging and the 2026 EU packaging regulations checklist.
The definitive compliance position on any given format comes from an accredited laboratory assessing that format under your conditions. What a manufacturer can do is make that assessment straightforward rather than a scramble.
Food-Contact Packaging with Per-Format Documentation
Ekoroll supplies paper cups, kraft containers and molded fiber packaging wholesale to restaurants, cafés, delivery brands and horeca distributors across Europe, with test reports and Declarations of Conformity issued per format rather than per catalogue. Explore our complete eco-friendly packaging range or contact us with your formats and intended use for the matching documentation.
