Heavy metals in packaging: what evidence to get
Obtain a packaging material list, a signed supplier declaration and supporting technical evidence tied to your approved specification and production materials. Check that the combined regulated metals meet the packaging and component limit, with inks and coatings included in the assessment. Ask Cambridge China Bridge to coordinate evidence with its staff in China.
Specify the combined limit
GOV.UK identifies cadmium, mercury, lead and hexavalent chromium. The general limit is a combined concentration of 100 parts per million in packaging or any packaging component, subject to specific exceptions. It is not a separate allowance for each metal. Ask the supplier to state this combined limit explicitly rather than simply declaring the packaging “heavy-metal free”.
This guide covers the evidence behind that statement. For board grades, print approval, physical performance and freight considerations, use our packaging sourcing guide.
Map board, print and added materials
Request a material list linked to the approved packaging drawing and artwork revision. Include board, each ink colour, varnish, coatings, laminating film, adhesives, labels, inserts, closures and other supplied parts. Record the factory’s material codes and upstream suppliers so documents can be matched to what production actually uses.
Ask the laboratory to explain which items it will assess as packaging components and how permanent inks, pigments and coatings are included in the relevant finished component. An unprinted board report leaves the printed finish unexplained. Keep supporting ink and coating data, but ask for a clear assessment of the finished construction.
Build a traceable evidence pack
Request a signed, dated declaration naming the supplier, packaging specification, materials covered and combined metal limit. Ask for the basis of the declaration: upstream material declarations, composition information, test reports or an explained assessment. A generic factory certificate without identifiable packaging or supporting evidence is a reason to investigate further.
Where testing is used, match report photographs, sample descriptions and material codes to your approved packaging. Keep sample selection and dispatch records, especially when the factory sends samples directly. Our guides explain test report verification and laboratory sample traceability.
Brief the laboratory before accepting a result
Ask for concentration results for the named metals, the combined result, methods, units and reporting limits. Ask how hexavalent chromium is addressed if the report only lists total chromium. Have the laboratory explain whether its results support the combined limit, including how values reported as “not detected” are handled.
Ask the laboratory to justify coverage of different print colours, finishes and material sources. Do not accept a whole-pack average without an explanation of component coverage. When documents are incomplete, inconsistent or close to the limit, agree further evidence or testing before approving shipment.
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Connect approval to production
Make evidence review a purchasing approval gate. Keep the approved specification, declaration, supporting reports, sample records and production material references together. Ask the factory to flag changes to board sources, recycled feedstock, ink formulations, coatings or subcontracted printing before using them.
Follow our material substitution guide when a change is proposed. Ask Cambridge China Bridge’s staff in China to reconcile factory documents with production materials and arrange sample collection where needed. Agree who reviews the evidence and who authorises release before the shipment is ready.
Frequently asked questions
What is the UK packaging heavy-metal limit?
The general limit is 100 parts per million for the combined cadmium, mercury, lead and hexavalent chromium in packaging or any packaging component, subject to specific exceptions.
Is a board test report enough for printed cartons?
It leaves inks, coatings and other added materials unexplained. Request their supporting evidence and ask the laboratory to explain coverage of the finished printed component.
Can I accept a supplier’s heavy-metal-free declaration?
Ask what supports it. Match the declaration to your packaging specification and production materials, then review the underlying material information, reports or explained assessment.
Does not detected mean the packaging passes?
Ask the laboratory to explain reporting limits and how undetected results are handled in the combined assessment. The wording alone does not show whether the evidence supports the limit.