No. The 100 mg/kg limit for the sum of lead, cadmium, mercury and hexavalent chromium (Article 5, paragraph 4) applies to all packaging. The reference to food-contact materials in that paragraph preserves the specific food-contact rules without restricting its scope. Only the PFAS limits (Article 5, paragraph 5) apply exclusively to food-contact packaging. Industrial or medical packaging must therefore demonstrate compliance with the heavy metal limit in its technical documentation.
Read the source article: PPWR EU declaration of conformity: required contents