Heavy Metals and PFAS in Packaging Films: What Test Reports Should Show
Key Takeaways
- Heavy metals testing (Pb, Cd, Hg, As) is mandatory for food contact packaging films under EU, FDA, and Chinese GB 4806 regulations —a 'pass' statement without numerical data is not a compliance document.
- PFAS analysis is increasingly required for barrier films; 'not detected' results are meaningless without a stated limit of quantification (LOQ) and the test method used.
- A qualified test report must show the accredited laboratory, test method numbers, regulatory limits, and numerical results for every analyte —not a simple pass/fail.
- Natural cellulose films like XIADE's coated cellulose are inherently PFAS-free by formulation, which simplifies compliance for buyers in the EU and North America.
I have spent fifteen years in materials science, working with medical device and food packaging buyers who need to balance barrier performance, sterilization compatibility, and EU sustainability requirements at industrial scale. One of the most persistent sources of confusion I encounter is the interpretation of heavy metals and PFAS test reports for packaging films. Buyers receive a thick stack of paper —sometimes in Chinese, sometimes in English, occasionally in a format that looks like it was generated by a printer from 2005 —and are left wondering whether their packaging actually complies with regulations in their target market.
The problem is that a test report is only as valuable as the information it contains. A sheet that says "compliant" tells you nothing actionable. One that shows explicit lead at 0.003 mg/kg against a limit of 0.01 mg/kg, with CNAS accreditation and EN 15763 methodology referenced —that is a document you can use. This guide is about reading the difference.
Why Heavy Metals Testing Is Non-Negotiable for Food Contact Films
Heavy metals testing for food contact materials is not a quality bonus —it is a regulatory requirement in virtually every major market. Metals such as lead (Pb), cadmium (Cd), mercury (Hg), and arsenic (As) can migrate from packaging films into food contents under storage conditions, creating cumulative dietary exposure risks. These four analytes are specifically regulated because they are the most common industrial contaminants in polymer coatings, printing inks, and additive packages used in film manufacturing.
In the European Union, Regulation (EC) No 1935/2004 establishes (source: EU Official Journal) the overarching framework requiring that food contact materials do not transfer constituents to food in quantities that could endanger human health. Specific limits for heavy metals are set in the CMR substances regulation (EU) 2018/775 and in individual material-specific directives. The German BfR recommendations, French DGCCRF guidelines, and Italian DMH regulations all reference common heavy metals limits that are broadly consistent with each other.
In the United States, the FDA regulates heavy metals in food contact substances under the Toxic Substances Control Act (TSCA) and Food, Drug, and Cosmetic Act FDA Food Contact Substances Guidance. While the FDA does not publish a single consolidated table of heavy metals limits for all packaging materials, it has established specific migration limits for lead, cadmium, and mercury in ceramic, glass, and coated surfaces —and importers of food contact articles are expected to demonstrate compliance through supplier declarations and batch-specific testing.
In China, the GB 4806 series standards —particularly GB 4806.7 for general plastics and GB 4806.8 for paper and paperboard —establish specific heavy metals limits. SAMR Standards Portal. SAMR Standards Portal. GB 4806.8-2022 sets limits for Pb, Cd, Hg, and As at 0.01 mg/kg for Pb, 0.002 mg/kg for Cd, 0.002 mg/kg for Hg, and 0.01 mg/kg for As in paper-based food contact materials.
"We have seen buyers accept test reports for coated films that only covered four heavy metals and excluded PFAS entirely —because no one asked about PFAS in 2019. That gap in 2026 can mean a container held at customs in Rotterdam or a product recall in Malaysia." —Yusheng Yan, Senior Materials Scientist & Technical Director, XIADE
What the Test Report Must Contain: The Five-Point Verification
Before accepting any test report as evidence of compliance, verify these five elements. Absence of any one of them is a red flag.
1. Accredited Laboratory Identification
The report must clearly identify the testing laboratory with its accreditation body and accreditation number. The most widely recognized international accreditation is ISO/IEC 17025. In China, look for CNAS accreditation. In the EU, a laboratory may be accredited by a national body such as DAkkS (Germany), COFRAC (France), or UKAS (UK).
A report from an unaccredited internal laboratory or a non-named "third-party testing institute" carries no regulatory weight. If the laboratory is accredited, you can verify the accreditation number on the accreditation body's public database —a step that takes thirty seconds and can save significant downstream risk.
2. Explicit Test Method Numbers
Every analyte must be referenced to a specific standard method. For heavy metals in packaging films, widely accepted methods include EN 15763, GB/T 5009.11/33/37/74 series, EPA Method 200.8 / 6020B, and USP <233>. The method number on the report must match an actual published standard. "Method in-house-001" is not a recognized test method for regulatory compliance.
3. Numerical Results vs. Regulatory Limits
For each analyte, the report must show both the measured value and the applicable regulatory limit, side by side.
| Analyte | Test Result (mg/kg) | Regulatory Limit (mg/kg) | Assessment |
|---|---|---|---|
| Lead (Pb) | 0.003 | 0.01 (GB 4806.8 / EU 1935/2004) | Pass |
| Cadmium (Cd) | <0.001 | 0.002 (GB 4806.8 / EU 1935/2004) | Pass |
| Mercury (Hg) | <0.001 | 0.002 (GB 4806.8 / EU 1935/2004) | Pass |
| Arsenic (As) | 0.002 | 0.01 (GB 4806.8 / EU 1935/2004) | Pass |
If the report states only "pass" or "compliant" without the underlying numbers, it is not a compliance document —it is a marketing claim.
4. Limit of Quantification (LOQ) for Every Analyte
For each result reported as "not detected" or "ND," the report must state the limit of quantification (LOQ) —the minimum concentration the method can reliably detect and quantify. Without the LOQ, "not detected" means nothing. A result of "ND" with LOQ of 0.5 mg/kg is completely different from "ND" with LOQ of 0.001 mg/kg.
For regulatory compliance, the LOQ must be below the applicable limit. If the regulatory limit for cadmium is 0.002 mg/kg and the lab reports "ND" with LOQ of 0.005 mg/kg, the test is uninformative.
5. Sample Identification and Batch Traceability
The report must describe the tested sample with sufficient specificity to allow traceability: product name or code, manufacturing batch number, production date, film thickness or grade designation, and the quantity tested. A report that says "tested one roll of film" without batch identification cannot be linked to a specific production run.
PFAS in Packaging Films: The Emerging Compliance Frontier
PFAS (per- and polyfluoroalkyl substances) represent the most significant emerging regulatory challenge in food contact packaging as of 2026. These chemicals —which include thousands of individual compounds —have been used in some coating formulations for their oil and grease resistance, moisture barrier properties, and thermal stability. The problem is that certain PFAS, particularly PFOS (perfluorooctane sulfonic acid) and PFOA (perfluorooctanoic acid), are persistent, bioaccumulative, and potentially toxic.
The EU has moved aggressively. Under the REACH restriction proposal on PFAS, the EU is pursuing one of the world's most comprehensive restrictions. For food contact materials, EFSA has established specific limits for PFOS and PFOA. In practice, this translates to very low limits on PFOS and PFOA in food contact materials —typically requiring LOQs in the parts-per-billion range.
In the United States, EPA's PFAS Strategic Roadmap and state-level regulations (California's Prop 65, Maine's LD 1911) are creating a patchwork of requirements. Federal mandatory limits for PFAS in food packaging are still evolving as of 2026.
For buyers sourcing coated or barrier films, you must ask specifically whether PFAS has been tested —not assume it has not been used. At XIADE, our coated cellulose films are formulated without any added PFAS compounds by design. We test specifically for PFOS and PFOA and publish those results on request.
How to Read a PFAS Test Report
PFAS testing is more complex than heavy metals testing because PFAS encompasses thousands of compounds.
Target Compound List
A meaningful PFAS test should cover a broad panel of compounds. At minimum, the panel should include PFOS and its salts, PFOA and its salts, PFNA, PFHxS, PFDA, and GenX chemicals (HFPO-DA and related compounds). If the report only lists PFOS and PFOA, ask whether the laboratory analyzed a broader panel.
Extraction and Analysis Method
Accepted methods for PFAS in packaging films include CEN/TS 15968 (determination of extractable PFAS in paper and board), ISO 25101 (PFOS and PFOA in water, adapted for solid matrices), and EPA 537.1. The report must state the extraction solvent, extraction time and temperature, and the analytical technique (typically LC-MS/MS).
Results Presentation
Similar to heavy metals, PFAS results must show numerical values and LOQs for each compound. "Screened for PFAS —no compounds detected" is not a compliance document.
"When a buyer asks me whether XIADE's coated cellulose film contains PFAS, I can say with confidence: our formulation contains no intentionally added PFAS compounds, and our test results for PFOS and PFOA consistently show non-detect at LOQs of 0.001 mg/kg or lower. I want them to see the data —not take my word for it." —Yusheng Yan, Senior Materials Scientist & Technical Director, XIADE
Market-Specific Compliance Requirements
European Union
The EU requires compliance with Regulation (EC) No 1935/2004 for all food contact materials. For heavy metals, the French DGCCRF and German BfR framework are the most commonly referenced. For PFAS, EFSA limits and the evolving REACH restriction are the primary drivers. Request test reports that reference EN 15763 for heavy metals and CEN/TS 15968 for PFAS.
United States
The FDA regulates food contact substances under the Federal Food, Drug, and Cosmetic Act. State-level requirements —particularly California's Proposition 65 —can impose stricter requirements than federal law. A product legal at the federal level may require Prop 65 warnings in California if it contains lead or specific PFAS compounds above the state's Safe Harbor Levels.
China (GB 4806 Series)
China's GB 4806.8-2022 (Paper and paperboard) specifically sets limits for Pb (0.01 mg/kg), Cd (0.002 mg/kg), Hg (0.002 mg/kg), and As (0.01 mg/kg). Testing must be performed by laboratories recognized by China's State Administration for Market Regulation (SAMR).
Middle East and Southeast Asia
Halal-conscious markets in the Middle East and Southeast Asia reference a combination of EU and international standards. Saudi Arabia's SASO and the UAE's ESMA reference EN standards and EU regulations for heavy metals and PFAS, with additional requirements for Halal compliance.
How XIADE's Cellulose Films Address This Compliance Landscape
XIADE premium natural cellulose films are formulated without intentionally added PFAS compounds. The cellulose base is derived from natural wood pulp, and the coatings are water-based or solvent-based systems that do not include PFOS, PFOA, or related long-chain PFAS in their formulation.
For heavy metals, our films are tested per EN 15763 and GB 4806.8-2022 as applicable, with results consistently showing levels well below regulatory limits. The primary concern is trace contamination from the coating system and printing inks used during conversion —and we test those specifically.
The limitation is that XIADE's films are not designed for every application. For buyers with specialized requirements, XIADE also offers flexible packaging film solutions and application-specific technical support. For buyers with specialized requirements, XIADE also offers flexible packaging film solutions and application-specific technical support. For high-temperature sterilization processes (retort conditions above 121C), alternative film constructions may be required. We conduct these tests with accredited laboratories and share results with buyers as part of our technical support process.
A Practical Checklist: What to Request from Your Film Supplier
Supplier Compliance Documentation Checklist
- ISO 17025 (or equivalent) accredited laboratory test report for heavy metals (Pb, Cd, Hg, As) with numerical results vs. regulatory limits
- PFAS test report covering at minimum PFOS and PFOA, with LOQ stated and numerical results
- Statement of food contact regulation compliance (EU 1935/2004, FDA, GB 4806 as applicable)
- Declaration of Substances of Very High Concern (SVHC) under REACH, if applicable
- Traceability information linking test report to specific production batch and date
- Current REACH/RoHS compliance declaration (for heavy metals and restricted substances)
- For EU market: EU food contact materials Declaration of Compliance (DoC) from the converter or film manufacturer
- For US market: FDA food contact substance notification (FCN) number or equivalent, if new substances are involved
- For Halal markets: HALAL certification from accredited body (covering the full manufacturing chain)
Request Technical Documentation for XIADE Films
XIADE maintains a full technical documentation package for each film grade, including heavy metals test reports, PFAS screening results, EU food contact declarations, and GB compliance data. Our technical team responds to documentation requests within two business days.
Contact XIADE Technical Team —/a>Frequently Asked Questions
What heavy metals are typically tested in food contact packaging films?
The most commonly tested heavy metals are lead (Pb), cadmium (Cd), mercury (Hg), and arsenic (As). These four are regulated under EU Framework Regulation (EC) No 1935/2004, the US FDA CPSC guidelines, and China's GB 4806 series standards. Testing is typically performed by ICP-MS or ICP-OES following EN 15763 or equivalent digestions.
What are PFAS and why do they appear in packaging films?
PFAS (per- and polyfluoroalkyl substances) are a broad class of synthetic chemicals used in some packaging films to provide oil and grease resistance, moisture barriers, and heat resistance. Certain long-chain PFAS (PFOA, PFOS) are restricted or banned in food contact materials in the EU and US. Short-chain PFAS and newer alternatives are still under regulatory review.
What specific test methods are accepted for PFAS in packaging films?
Accepted methods include ISO 25101, CEN/TS 15968, and EPA 537/537.1 adapted for film matrices. The test report must specify the limit of quantification (LOQ) —if it only states 'not detected' without specifying LOQ, the result is meaningless for regulatory compliance.
How do EU food contact regulations specifically address PFAS?
EFSA has established strict limits for PFOS and PFOA in food. PFOS must not exceed 0.01 mg/kg and PFOA must not exceed 0.025 mg/kg in food contact paper and board materials. Cellulose-based films like XIADE's products contain no added PFAS by formulation.
What should a qualified test report for food contact packaging look like?
A qualified test report must contain: (1) accredited laboratory name and accreditation number (CNAS, ISO 17025), (2) sample description and batch/date code, (3) explicit test methods referenced by number, (4) regulatory limits stated alongside each result, (5) LOQ for each analyte, (6) numerical results —not just 'pass' or 'fail'.