Heavy metals and packaging composition in Slovakia: the 100 mg/kg limit

Methodology: Marek Galetka, founder of Pravano. English translation of our Slovak article, which a person approved before publication; every number, date and legal reference of the translation is checked automatically against the original.

Cross-checked as of 25 September 2026 · based on primary sources

Updated 25 September 2026. Based on Act No. 79/2015 Coll. on Waste. An informative readiness check, not a legal service or an official audit. Original: slovenská verzia.

The obligations of a producer of packaging do not concern only registration and waste collection. Act No. 79/2015 Coll. also sets requirements for the composition of the packaging itself, in particular for its heavy metal content. These rules apply to every piece of packaging placed on the Slovak market and are checked independently of fulfilment through a producer responsibility organisation (PRO).

Requirements on the composition and recoverability of packaging

Under Section 53(1), packaging must allow reuse or recovery (recycling, energy recovery and the like) and meet harmonised standards. These are properties of the packaging itself, independent of how you fulfil your reserved obligations.

Heavy metal limit: 100 mg/kg

It is prohibited to manufacture and place on the market packaging in which the combined content of lead, cadmium, mercury and hexavalent chromium exceeds 100 mg/kg (Section 53(3)), with the exceptions set out in paragraph 4. The limit applies to the sum of these four metals, not to each of them separately.

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Consistency with the PPWR

Article 5 of the PPWR, Regulation (EU) 2025/40, sets the same limit of 100 mg/kg. Here the Slovak rules and the EU regulation coincide, so there is no conflict between the national and the EU layer for you. On this point, Section 53 of the Waste Act is still based on the older Directive 94/62/EC; since the PPWR has applied directly since 12 August 2026, it is worth following the amendment to the Waste Act that the ministry is preparing to align it with the PPWR.

What you risk and what to check

A breach of the limit (Section 53(3)) is punishable by a fine of €4,000 to €350,000 (Section 117(6)). In practice, the safest course is to ask your packaging supplier for a document or declaration that the packaging meets the heavy metal limit, and to keep it in case of an inspection. Supervision is carried out by the Slovak Environmental Inspectorate.

Primary sources

Frequently asked questions

What is the heavy metal limit for packaging?

The sum of the concentration levels of lead, cadmium, mercury and hexavalent chromium in packaging must not exceed 100 mg/kg (Section 53(3) of Act No. 79/2015 Coll., with exceptions in paragraph 4). Article 5 of the PPWR sets the same limit, so there is no conflict.

Whom does the limit concern?

It is prohibited to manufacture and place on the market packaging that exceeds the limit. It therefore concerns the manufacturer of packaging as well as anyone who places packaging or packaged goods on the Slovak market.

What other requirements apply to packaging?

Under Section 53(1), packaging must allow reuse or recovery and meet harmonised standards. These are requirements on the composition and recoverability of packaging, independent of registration and fulfilment through a PRO.

What fine applies?

A breach of Section 53(3) is punishable by a fine of €4,000 to €350,000 (Section 117(6) of Act No. 79/2015 Coll.).