Do you know if there are any guidance documents associated with this regulation that might identify particular packaging products that are at higher risk of not complying with this regulation?
Few guidance documents specifically for Packaging exist other than content speaking to the subject of how to ensure label readability: http://ec.europa.eu/health/sites/health/files/files/eudralex/vol-2/c/2009_01_12_readability_guideline_final_en.pdf.
Regulations and guidelines will not name a specific type of product is at higher risk of not complying, however, Glass packaging, Plastic Crates and Pallets that contain recycled glass or plastic are allowed to have heavy metals above threshold as long as no additional heavy metals are added via specific regulations providing a derogation.
Reference (Plastic Degradation): http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001D0171
Reference (Glass Degradation): http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32001D0171)