Article 5 of Regulation (EU) 2025/40 (PPWR) keeps the historic packaging heavy-metal rule: the sum of lead, cadmium, mercury and hexavalent chromium present in packaging or packaging components must not exceed 100 mg/kg by weight. This paper walks through a real, anonymised 16-component test report produced to the IEC 62321 series and shows exactly how a battery exporter demonstrates compliance for every box, tray and film.
The 100 mg/kg (100 ppm) ceiling applies to the combined concentration of the four metals in each homogeneous packaging component — not averaged across the whole shipment. It descends from Directive 94/62/EC and is preserved unchanged in the PPWR, but the surrounding documentation regime is stricter: from 12 August 2026 the result must sit inside a technical file, support an EU Declaration of Conformity and remain available for market-surveillance inspection. A single component above the cap fails the whole packaging type, regardless of how clean the others are.
Accredited determination follows the IEC 62321 series, the same method family used for electrical-equipment substances. Lead and cadmium are determined per IEC 62321-5:2013, mercury per IEC 62321-4:2013 (amended 2017), by digestion followed by inductively coupled plasma optical-emission spectrometry (ICP-OES), with ICP-MS available for ultra-trace work. Hexavalent chromium follows IEC 62321-7-2:2017 for polymers and electronics and 62321-7-1:2015 for metallic surfaces with coatings, using alkaline extraction and UV-visible spectrophotometry. A practical method detection limit is 2 mg/kg per metal; results below it are reported "N.D." (not detected) with the detection limit stated, rather than as zero.
The reference report (an accredited Shenzhen laboratory, issued June 2026 for a battery-industry applicant) sampled sixteen packaging components: white paper card, colour-printed blue plastic, transparent plastic blister, clear film, kraft paper, copper metal elements and additional paper/plastic/metal parts. Each homogeneous component was tested separately for all four metals. Fifteen components returned N.D. for every metal; the single copper-metal component measured 19 mg/kg lead with cadmium, mercury and CrVI not detected. The combined worst-case value of 19 mg/kg sits at roughly one fifth of the 100 mg/kg cap — a pass with wide margin. The case illustrates three practical truths: printing inks and pigments are the usual lead/cadmium risk points; metallic elements can carry trace lead from alloying; and a well-controlled supply chain routinely returns non-detects.
Defensible results depend on sampling: test each homogeneous material separately (a printed carton splits into board, ink layer and varnish where they differ); sample from production-representative lots; retain specimen identifiers linking to batch records; and re-test whenever a material, ink supplier, printing process or colour changes — a new Pantone colour is a new substance profile. Reports must show laboratory accreditation scope, method edition, detection limits, individual metal values, the summed value and an explicit conclusion against the 100 mg/kg limit. XRF screening is useful as an incoming-goods gate but does not replace wet chemistry in the conformity file.
The test report feeds the PPWR Annex VIII technical file for that packaging type and is cited in its EU Declaration of Conformity under the harmonised-specification references. Keep a matrix: packaging component → material → supplier → report number → result → declaration. When a customer asks "do you meet Article 5?", the answer is the matrix plus the reports, not a generic statement. The same reports support REACH and customer social-audit questionnaires, so the testing effort is reused across PPWR, battery-law and commercial audits.
Weijiang Power tests every NiMH packaging component to IEC 62321 by accredited laboratories, holds per-component Pb/Cd/Hg/CrVI reports at 2 mg/kg detection limits and cites them in separate PPWR Declarations of Conformity for primary, secondary and tertiary packaging. Request our heavy-metal report set and component matrix and you will see values at or near non-detect with comfortable margin under the 100 mg/kg combined limit.
