REACH: what the European chemicals regulation asks of packaging
A plastic bottle is not a chemical product. Under European law, however, it is an "article" that contains substances, and REACH applies to it. For a manufacturer selling in Europe, the question is not whether the regulation concerns it, but how.
By Tecmom editorial team · 2 min read
A regulation on substances, wherever they are
Regulation (EC) No 1907/2006, known as REACH, governs the registration, evaluation, authorisation and restriction of chemical substances in the European Union. It covers substances on their own, in mixtures, and in articles, that is, objects whose shape matters more than their chemical composition. A bottle, a cap and a tube are articles.
Polymers themselves are exempt from registration; the monomers used to make them, and additives, are not.
The Candidate List and the 0.1% threshold
REACH identifies substances of very high concern (SVHCs): carcinogens, reproductive toxicants, persistent and bioaccumulative substances, endocrine disruptors. The European Chemicals Agency (ECHA) places them on a Candidate List, which it usually extends twice a year.
Article 33 then creates a duty to inform. The supplier of an article containing a substance on this list above 0.1% by weight must inform its business customer, at least by giving the substance's name. A consumer may ask for the same information, which must be provided within 45 days.
The Annex XVII restrictions
Beyond information, REACH bans or limits certain substances in certain uses: this is Annex XVII. The restriction on intentionally added microplastics, adopted in 2023, is a recent example; see microplastics and packaging.
REACH does not replace food contact rules, which set what may migrate from a pack into food. Both apply together.
For a manufacturer outside the Union
REACH obligations fall on operators established in the Union: the importer of packaging made in Morocco, for example, must be able to answer for what it places on the market. It therefore turns to its supplier, who must know the composition of its materials, colourants and additives, and follow updates to the Candidate List.
It is a matter of documentation more than of manufacturing: declarations from resin and masterbatch producers, batch traceability, up-to-date information. The topic links up with the PPWR, which governs packaging itself.
REACH does not ask for a bottle to be made differently. It asks whoever sells it to know exactly what it contains.
Glossary
- REACH
- The European regulation on the registration, evaluation, authorisation and restriction of chemicals.
- Article
- Under REACH, an object whose shape determines its function more than its chemical composition.
- SVHC
- A substance of very high concern, placed on ECHA's Candidate List.
- Masterbatch
- A pellet concentrated in colourant or additive, diluted into the material during processing.