If you manufacture, import, or sell packaging in the EU, REACH isn’t optional paperwork — it’s a chemical restriction regime that can hold up a shipment at customs or trigger a recall if you get it wrong. The rules cover everything from printed cardboard to plastic film to the ink on a label, and the obligations differ depending on what’s actually in your materials.
This guide breaks down what REACH actually restricts in packaging, how the 0.1% SVHC threshold works in practice, what SCIP notification requires, and how packaging-specific rules under the EU’s newer Packaging and Packaging Waste Regulation (PPWR) stack on top of REACH. You’ll come away knowing exactly what to check before you sign off on a supplier’s packaging.
Quick Answer
REACH restricts packaging in two main ways: it bans or caps specific hazardous substances outright under Annex XVII (like certain phthalates and polycyclic aromatic hydrocarbons in inks and coatings), and it requires disclosure — and in many cases SCIP database notification — whenever a Substance of Very High Concern (SVHC) from the REACH Candidate List is present above 0.1% by weight in any packaging component. Separately, the EU’s Packaging and Packaging Waste Regulation (PPWR) adds its own hard limits on heavy metals and PFAS that apply directly to packaging, on top of REACH.
How REACH Actually Applies to Packaging
Under REACH, empty packaging counts as its own ‘article,’ assessed separately from whatever product it contains. That means a plastic tray, a printed carton, and a shrink-wrap film each need to be checked individually against the SVHC Candidate List — not just the finished, packed product as a whole. The Candidate List currently runs to roughly 250 substances and grows every time ECHA (the European Chemicals Agency) adds new entries, typically a couple of times a year, so a packaging component that was compliant last year can fall out of compliance without you changing a single supplier.
The core trigger is the 0.1% by weight threshold. If any SVHC is present in a packaging component above that concentration, two things follow. First, under REACH Article 33, the supplier must proactively tell business customers which substance is present and give enough information for safe use — this applies even below any registration or authorization threshold. Second, since 2021, EU-based suppliers placing such articles on the market generally must notify the substance and its location to ECHA’s SCIP database (Substances of Concern In articles, as such or in complex objects), which feeds waste operators and recyclers, not just regulators.
It’s worth separating REACH’s SVHC/Candidate List mechanism from REACH’s Annex XVII restrictions, which are outright bans or hard concentration limits regardless of Candidate List status. Annex XVII is where you’ll find limits relevant to printing inks and coatings used on packaging — for example, restrictions on polycyclic aromatic hydrocarbons (PAHs) in materials that see prolonged skin contact, and limits on certain phthalates in plasticized materials. These apply whether or not the substance is separately listed as an SVHC.
PPWR: The Newer Packaging-Specific Rules Layered on REACH
REACH is the general EU chemicals law, but packaging now has its own dedicated regulation too: the Packaging and Packaging Waste Regulation (EU) 2025/40, or PPWR. From 12 August 2026, PPWR sets a combined concentration limit for four heavy metals — lead, cadmium, mercury, and hexavalent chromium — of 100 mg/kg (100 ppm) across all packaging placed on the EU market, regardless of contents. This is a combined limit, not a per-substance one, so you can’t max out each metal individually.
PPWR also introduces its own PFAS (‘forever chemicals’) restriction specifically for food-contact packaging, effective the same date: 25 ppb for any individual PFAS substance, 250 ppb for the sum of non-polymeric PFAS, and 50 ppm for total PFAS including polymeric forms. There’s no grandfathering — packaging placed on the market after the deadline must comply regardless of manufacture date. This sits alongside a separate, broader PFAS restriction proposal moving through REACH’s own evaluation process, which covers far more sectors and substances but is on a longer timeline. Don’t confuse the two: PPWR’s PFAS limits for food-contact packaging land first.
Tips and Common Mistakes
Check every component, not just the finished pack. A compliant box with non-compliant ink, adhesive, or coating still fails. Assess labels, tapes, and closures as separate articles too.
Don’t treat one supplier declaration as permanent. The SVHC Candidate List is updated multiple times a year, so a ‘REACH compliant’ certificate from 18 months ago may already be stale — ask suppliers for current, dated declarations tied to the latest Candidate List version.
Distinguish REACH Article 33 communication from SCIP notification — they’re related but not interchangeable. Completing a SCIP submission does not, on its own, satisfy your Article 33 duty to inform customers, and vice versa.
If you sell food-contact packaging into the EU, track PPWR’s heavy metal and PFAS limits separately from your REACH SVHC screening — they’re different legal instruments with different thresholds and the same 12 August 2026 deadline.
Get material declarations in writing from every packaging supplier, including overseas ones. REACH obligations for imported articles fall on the EU importer, so a supplier’s silence or vague assurance is your liability, not theirs.
Explore more: More packaging compliance guides.
REACH Compliance for Packaging FAQs
What is the REACH SVHC threshold for packaging?
0.1% by weight of any single Substance of Very High Concern (SVHC) from the REACH Candidate List, assessed for each individual packaging component (box, film, label, closure) rather than the packed product as a whole.
Is packaging considered an ‘article’ under REACH?
Yes. Empty packaging is treated as its own article, separate from the product it contains, and must be assessed against REACH obligations independently.
Do I need to notify the SCIP database for packaging?
If your packaging contains an SVHC above 0.1% by weight and you’re placing it on the EU market as a manufacturer, importer, or assembler, you generally need to submit a SCIP notification to ECHA, in addition to your Article 33 communication duty to customers.
How is REACH different from the PPWR heavy metals and PFAS rules?
REACH is the EU’s general chemicals regulation and governs SVHCs and Annex XVII restricted substances across all articles. PPWR (Regulation (EU) 2025/40) is packaging-specific and sets its own hard limits — a combined 100 mg/kg cap on lead, cadmium, mercury, and hexavalent chromium, and separate PFAS limits for food-contact packaging — both effective 12 August 2026. Packaging must satisfy both frameworks.
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