Stretch Film Under PPWR: Heavy Metals, PFAS and Testing Rules

Stretch Film Under PPWR: Heavy Metals, PFAS and Testing Rules

Since 12 August 2026, the EU Packaging and Packaging Waste Regulation — PPWR, formally Regulation (EU) 2025/40 — has applied directly in all 27 Member States. It repeals Directive 94/62/EC, which had governed EU packaging rules for close to thirty years. For stretch film manufacturers and exporters, the most immediate change is commercial rather than technical: EU buyers now request test reports and an EU Declaration of Conformity (DoC) as a condition of shipment, and customs authorities can hold consignments when supporting documentation is missing.

One problem comes up repeatedly. Suppliers submit a RoHS report and expect it to clear. It does not. RoHS covers electrical and electronic equipment; PPWR covers packaging. The scope, the sampling logic and the limit values are different, and RoHS reports are being returned.

This guide works through nine practical questions: scope, layer-by-layer sampling, heavy metal limits, PFAS, the tests buyers commonly add, three typical testing scenarios, workflow and lead time, how to word a test request, and a pre-submission checklist.

1. Does PPWR apply to your stretch film?

Yes. PPWR applies to all packaging placed on the EU market regardless of material, and plastic stretch film falls under transport packaging.

Two points are regularly misunderstood.

First, Delegated Decision (EU) 2026/429 exempts stretch film and strapping used with pallets from the 100% reusable packaging target. That exemption covers one obligation only. Heavy metal testing, technical documentation and the Declaration of Conformity remain in force.

Second, for food-contact film — cling film and similar products intended to touch food directly — the PFAS restriction has applied since 12 August 2026. The European Commission has confirmed there is no general stock-exhaustion period. Packaging placed on the EU market before 12 August 2026 may stay on the market, but any packaging first placed on the market on or after that date must comply.

A useful detail for anyone preparing a DoC: from 12 August 2026 the conformity assessment and Declaration of Conformity cover Article 5(4) on heavy metals, Article 5(5) on PFAS in food-contact packaging, and — where relevant — Article 11(1) on reusable packaging. The recyclability requirement in Article 6 also applies from that date, but the conformity assessment procedure for it is not yet required, because the delegated acts setting out design-for-recycling criteria are still pending.

2. The rule that causes most rejections: layer-by-layer sampling

PPWR requires each homogeneous material in a packaging unit to be tested separately. Averaging across different materials is not accepted. This is where most stretch film submissions fail.

Plain PE stretch film is normally a single homogeneous material and can be submitted as one sample. Printed stretch film is different. The ink layer and the base film must be separated, and the ink tested as its own homogeneous material. A printed section cannot be folded into the base film result to produce an average.

Different masterbatches and different ink colours must be tested separately as well. When layers are combined, two things happen: the report is treated as invalid, and the laboratory rejects the sample.

3. Heavy metals: the 100 mg/kg floor

Every homogeneous material in a packaging unit — plastics, paper, metals, glass, inks, adhesives, coatings and tapes — must not exceed a combined concentration of 100 mg/kg for lead, cadmium, mercury and hexavalent chromium.

The requirement sits in Article 5(4) of Regulation (EU) 2025/40. Each homogeneous layer is tested independently, and results are assessed against the limit.

Two reminders worth repeating. A RoHS report does not substitute for this test. And the limit applies per homogeneous material, not to an average across the unit.

4. PFAS: what actually applies to food contact

For food-contact packaging, the limits under Article 5(5) are:

• 25 ppb for any individual PFAS measured by targeted analysis, excluding polymeric PFAS

• 250 ppb for the sum of PFAS measured by targeted analysis, excluding polymeric PFAS

• 50 ppm (50 mg/kg) for PFAS in total, including polymeric PFAS

Two clarifications matter in practice. The European Commission has confirmed these limits apply to the packaging unit as a whole — inks, coatings and adhesives included — and they apply whether PFAS were added intentionally or are present unintentionally.

For screening, Commission guidance describes a stepwise approach: test total fluorine first, and where the result exceeds the threshold, analyse organic fluorine and, if necessary, run targeted PFAS analysis. Where total fluorine exceeds 50 mg/kg, the manufacturer, importer or downstream user should be ready to show how much of the fluorine is attributable to PFAS and how much to non-PFAS substances.

Food-contact plastic packaging must also meet the overall and specific migration requirements of Regulation (EU) No 10/2011.

Non-food-contact packaging is not subject to a mandatory PFAS limit today. Voluntary screening is still worth considering, because buyers increasingly ask for it and a late request is more expensive than a planned test.

5. What buyers commonly add

Beyond the mandatory items, EU buyers and sector-specific procurement teams frequently ask for:

• REACH SVHC screening

• REACH Annex XVII restricted substances, including phthalates, bisphenol A and short-chain chlorinated paraffins

• Persistent organic pollutants under the POPs Regulation, including PFOS, PFOA and related compounds

Test reports are generally treated as valid for one year. Retesting is expected whenever the material, masterbatch or supplier changes.

6. Three typical testing scenarios

Scenario 1 — Industrial stretch film. Covers PE stretch film, machine film and cable wrapping film used as transport packaging. Testing covers the four heavy metals in the base film against the 100 mg/kg limit. For printed film, the ink layer is added as a separate homogeneous material with its own heavy metal test. Reports are issued by an ISO/IEC 17025-accredited laboratory.

Scenario 2 — Non-food-contact multilayer laminate. Each layer is separated and tested individually — print layer, adhesive layer, substrate layer, sealant layer — for the four heavy metals. Different masterbatches are tested separately. SVHC screening can be added.

Scenario 3 — Food-contact laminate. Covers cling film and food laminates intended for direct contact. Adds to Scenario 2 the PFAS parameters (25 ppb individual, 250 ppb sum, 50 ppm total including polymeric PFAS) and EU 10/2011 migration testing.

7. Workflow and lead time

Map the structure. List every layer, the ink colours used, and whether the film is intended for food contact. Most laboratories provide a template for this; a clear structure list is the single biggest factor in avoiding rework.

Prepare samples. At least 5 grams per homogeneous material. Where a coating cannot be separated, send the whole piece.

Complete the request form. State the legal basis — Regulation (EU) 2025/40 — and the intended use of the report, whether for customs clearance or for the Declaration of Conformity.

Allow for turnaround. Three to five working days is typical for heavy metal testing. In a recent submission, samples received on 10 August were reported on 13 August. Expedited handling can usually be arranged.

Archive the evidence. Keep the technical documentation and the Declaration of Conformity available for inspection: at least five years from the date the packaging is placed on the market for single-use packaging, and ten years for reusable packaging.

8. How to word the test request

An unclear request is the most common cause of rework. The following wording can be adapted:

We submit PE stretch film (printed) for testing of lead, cadmium, mercury and hexavalent chromium against the 100 mg/kg limit set out in Article 5(4) of Regulation (EU) 2025/40. Each homogeneous material is submitted separately and the ink is packed separately. For food-contact laminates, please add PFAS parameters under Article 5(5) and migration testing under Regulation (EU) No 10/2011. Please issue an accredited test report for use in an EU Declaration of Conformity.

9. Pre-submission checklist

• Has every homogeneous layer been separated, with no combined or averaged samples?

• Is the ink layer of printed film submitted separately, with each colour tested on its own?

• Are heavy metal results reported per layer and within the 100 mg/kg limit?

• For food contact, are PFAS parameters and EU 10/2011 migration testing included?

• Is the laboratory accredited to ISO/IEC 17025?

• Has anything changed in the material, masterbatch or supplier since the last report?

• Is a RoHS report being offered where a PPWR report is required?

A note on environmental claims

Since 27 September 2026, Directive (EU) 2024/825 on empowering consumers for the green transition has applied across the EU. Generic environmental claims such as "eco-friendly", "green" or "sustainable" are restricted unless supported by demonstrable performance, and presenting a legal requirement that applies to all products in a category as a distinctive feature of one’s own offer is treated as an unfair commercial practice. For packaging suppliers this means two things: avoid unqualified environmental claims in export documentation and marketing, and avoid presenting PPWR compliance itself as a competitive differentiator. Claims such as "recyclable" or "PFAS-free" should only be used where test evidence supports them.

The underlying shift in PPWR is from assessing a product to assessing each material within it. For stretch film, which looks structurally simple, the exposure is rarely in the base film. It sits in the ink layer, the adhesive layer and the masterbatch — the parts most often overlooked. Mapping the structure properly and writing a precise test request costs far less than reissuing a rejected report.

Disclaimer: This article is provided for general information only. It is based on Regulation (EU) 2025/40 and publicly available Commission and member-state guidance as of October 2026, and it is not legal advice. Requirements may be updated. Verify current wording against EUR-Lex and confirm your specific case with an accredited laboratory or qualified legal counsel.

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