The Impact of REACH on the Packaging Supply Chain

01 December 2007

A 13-page Guide to the EU's new chemicals legislation with packaging chain companies in mind. REACH--Registration, Evaluation, Authorisation and restriction of Chemicals--is probably the most extensive piece of environmental legislation ever introduced in the EU. This booklet outlines the duties and requirements for the different actors in the supply chain and offers a checklist of implementation steps.

The REACH Regulation, which entered into force on 1 June 2007, will impact on packaging as much as any other product. Clarity, Collaboration, and Communication (3 C’s) are essential to make REACH work.

Key recommendations for the packaging supply chain to comply with REACH are:

  1. The most urgent step to consider is pre-registration. Companies should begin to audit their product portfolios now and initiate dialogue with suppliers to ensure that all substances are pre-registered by the manufacturer or the importer. Indeed substances not pre-registered will not be allowed on the market after November 2008.
  2. In order to avoid cumbersome procedures, producers of packaging should endeavour to ensure that their packaging does not contain substances of very high concern in concentrations of more than 0.1 % (weight by weight). Substances of very high concern present in articles at a concentration of more than 0.1% will have to be notified to the European Chemicals Agency (EChA). Safety information on these chemicals will have to be communicated along the supply chain and also to consumers, but only upon request (see section 1.2 - 1.4).
  3. Companies which are downstream users of substances or preparations should inform their suppliers of how they use them, so that this identified use can be incorporated in the supplier’s registration dossier and in their Safety Data Sheet (SDS). You should however wait until the corresponding guidance documents and validated electronic tools are available before seeking use and exposure information from commercial partners.
    The aim of REACH is to ensure the good functioning of the internal market while achieving a high level of protection of human health and the environment. Undoubtedly, some substances will disappear from the market. Substances used in packaging could be among them.