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REACH vs. RoHS: Packaging Decisions Manufacturers Must Make in 90 Days

See how REACH and RoHS differ for manufacturers, what evidence to gather, and which packaging choices can reduce compliance delays and retailer setbacks.

Packaging materials being checked at a finishing area

If you manufacture or import electrical and electronic equipment, you need both regulations working at once: REACH governs chemical substances across your entire bill of materials, while RoHS restricts specific substances inside EEE at the homogeneous-material level. Screen your BOM for Substances of Very High Concern above 0.1% weight by weight and prepare SCIP and Article 33 communications; in parallel, gather homogeneous-material test evidence or supplier declarations to confirm RoHS compliance.

TL;DR:
- For each article, screen SVHC content above 0.1% by weight; submit SCIP data, pass SVHC information to professional customers automatically when you supply the article, and answer consumer requests within 45 days.
- For electrical and electronic equipment, test every homogeneous material separately; RoHS limits are generally 0.1% by weight, but cadmium is capped at 0.01%.
- Packaging usually falls outside RoHS unless it contains electronics, but inks, coatings, adhesives, and substrates still need REACH screening and supplier documentation.
- Notify ECHA when an SVHC present above 0.1% in your articles exceeds one tonne in total across those articles annually; new Candidate List entries give producers and importers six months before notification duties apply.

Table of Contents

1. What REACH requires from suppliers and importers

REACH treats most finished products you place on the EU market, including packaging, as "articles," and once a substance on the Candidate List appears above 0.1% w/w in that article, specific duties kick in. The ECHA guidance on candidate list obligations walks through how to calculate that threshold per article and when notification duties are triggered.

Two obligations matter most for product teams:

  • Article 33 requires you to inform professional customers, including retailers and distributors, automatically when you supply the article, and to provide sufficient information for safe use to consumers within 45 days of a request, whenever an SVHC exceeds 0.1% w/w.
  • Article 7(2) requires notification to ECHA when a producer or importer places articles containing that SVHC above 0.1% w/w on the market and the total quantity of the SVHC itself in those articles exceeds 1 tonne per year, and new Candidate List entries carry a 6-month window before notification duties apply.

Since 5 January 2021, the EU Waste Framework Directive (Directive 2008/98/EC) has required producers, importers and distributors placing articles containing a Candidate List SVHC above 0.1% w/w on the EU market to submit structured notifications to the SCIP database maintained by ECHA before those articles reach shelves. Suppliers who repeatedly place similar articles can reduce the notification burden by grouping submissions or referencing data already filed, rather than resubmitting from scratch each time.

2. How RoHS scope and Annex II substances apply to EEE

RoHS, formally Directive 2011/65/EU on the restriction of hazardous substances, applies to electrical and electronic equipment across eleven categories, from large household appliances to medical devices and monitoring instruments. Unlike REACH, which assesses the whole article, RoHS measures concentration at the homogeneous-material level, meaning each material that cannot be mechanically separated into distinct substances, such as a single plastic housing or a solder joint, must independently meet its limit.

That distinction matters operationally: a connector assembled from five different plastics and metals needs five separate measurements, not one average across the whole part.

Commonly restricted substances under RoHS Annex II include:

  • Lead, mercury, cadmium, and hexavalent chromium, along with several brominated flame retardants.
  • Four phthalates added in a later amendment, each capped at specific homogeneous-material limits.

Manufacturers who cannot yet substitute a restricted substance in a specific application can apply for an exemption under Annex III or IV. The European Commission's RoHS implementation page notes that renewal applications go through scientific assessment and stakeholder consultation that typically takes around 10 months, so exemption planning needs a long lead time.

3. Comparing REACH and RoHS where they overlap

REACH and RoHS answer different questions, and conflating them is one of the most common compliance mistakes we see in procurement teams handling EEE.

  1. Product scope: REACH covers virtually any article placed on the EU market; RoHS covers only electrical and electronic equipment within its listed categories.
  2. Measurement level: REACH calculates SVHC concentration across the whole article; RoHS calculates restricted-substance concentration within each homogeneous material inside that article.
  3. Legal consequence: A REACH SVHC trigger creates a communication and notification duty, not an automatic ban; a RoHS breach is a market-access violation tied to CE marking.
  4. Enforcement focus: REACH enforcement checks documentation, labeling and Article 33 communication, while SCIP filings fall under national rules implementing the EU Waste Framework Directive; RoHS enforcement checks laboratory test results against Annex II limits.

When your product is EEE, run both checks in sequence: confirm RoHS homogeneous-material compliance first, since that is a binding market-access requirement, then run the REACH SVHC screen across the full assembled article, since a component can pass RoHS and still trigger SCIP and Article 33 duties.

4. Thresholds, overlapping substances, and what evidence to keep

Several substances appear in both frameworks but with different thresholds and legal effects, which is exactly where compliance teams get tripped up. Lead and cadmium show up on both the RoHS Annex II list and, in certain applications, the REACH Candidate List or Annex XVII restricted-substances list. Annex XVII restrictions function as hard bans or conditional limits, distinct from the Candidate List's communication-only trigger.

Since 5 January 2021, the SCIP database, which comes from the EU Waste Framework Directive (Directive 2008/98/EC) rather than REACH, has used the same 0.1% w/w Candidate List trigger as REACH Article 33, whose 45-day consumer response window is a separate REACH rule unrelated to SCIP, and that single threshold drives most of the paperwork obligations manufacturers face under REACH and SCIP.

RoHS limits are generally set at 0.1% by weight for most restricted substances, with a stricter 0.01% limit for cadmium specifically.

Evidence worth collecting and retaining includes:

  • Homogeneous-material lab reports showing concentration results against each Annex II limit.
  • Signed supplier declarations covering material composition and any SVHC content.
  • IUCLID or SCIP-ready data fields supplied directly by vendors, formatted for notification.
  • Material certificates that identify resin grades, pigments, coatings, and adhesive chemistries.

5. A step-by-step compliance process for manufacturers and importers

Compliance work is manageable when it is broken into a repeatable sequence rather than treated as an annual scramble.

  1. Map your bill of materials down to the component level, and treat each component as its own "article" for REACH calculations rather than averaging across the finished product.
  2. Collect supplier declarations and certificates of compliance for every material, prioritizing components with plastics, coatings, solder, or surface finishes.
  3. Commission homogeneous-material lab testing to close any gaps that supplier paperwork does not cover, particularly for RoHS Annex II substances.
  4. Prepare SCIP submissions once a component crosses the 0.1% w/w SVHC threshold, and document the Article 33 communications sent to professional customers.
  5. Retain a technical file containing test reports, declarations, and notification confirmations, since this is what regulators and retailers will request during an audit.
  6. Set up ongoing monitoring: watch for new Candidate List entries every six months, track exemption renewal deadlines, and re-audit suppliers annually.

Pro Tip: Build your supplier declaration template once, require it for every new material, and you will avoid chasing the same paperwork six months into a product launch.

6. A packaging perspective on material choices and supplier questions

Packaging materials carry their own SVHC and substance risks, and the questions we ask our material suppliers mirror the compliance questions electronics manufacturers ask their component vendors. Coated papers, inks, laminates and adhesives can each introduce substances that trigger REACH communication duties if nobody checks them before production starts.

Our approach centers on asking suppliers for specifics before a material ever reaches a production run:

  • We favor certified paperboard stocks and inks with documented formulations over unverified alternatives, since undocumented additives are the most common source of late-stage compliance surprises.
  • We ask vendors for material specifications and transparent formulation information rather than accepting a generic safety data sheet.
  • We request IUCLID or SCIP-ready data fields directly from material suppliers so that notification work does not start from a blank page.
  • We standardize material declaration templates and sample-testing protocols across projects, which keeps every audit trail consistent from one order to the next.

7. What REACH and RoHS mean for beauty, spirits, and lifestyle packaging

Rigid boxes, labels and cartons count as articles under REACH, and the substances in the coated papers, printing inks, foil stamping, and adhesives used to make them become part of those articles, even though RoHS itself does not apply to packaging unless that packaging is sold with embedded electronics. That distinction trips up a lot of brand teams who assume RoHS covers packaging simply because it ships alongside an electronic product.

For beauty, spirits, and lifestyle brands, the practical REACH exposure sits in a handful of specific materials: pigments used in gravure or offset inks, adhesive formulations in pressure-sensitive labels, coatings applied for soft-touch or gloss finishes, and metallic foils used in hot-stamping. Any of these can carry an SVHC into the finished box or label, and if that SVHC exceeds the 0.1% w/w threshold in the article, it would trigger the same Article 33 communication and SCIP notification duties that apply to a plastic housing on a consumer electronic device.

Retailers in EU markets increasingly ask packaging suppliers for the same kind of substance declarations that electronics buyers expect from component vendors. A brand launching a limited-edition gift box with a new ink supplier faces real exposure if nobody checks that ink's pigment formulation against the Candidate List before the first production run.

This is where packaging-specific due diligence earns its keep: confirming ink, coating, and adhesive formulations in writing before committing to a print run protects both the launch timeline and the brand's standing with EU retail partners.

8. Where packaging obligations diverge from EEE manufacturer duties

Packaging manufacturers and EEE manufacturers both answer to REACH, but RoHS creates an obligation gap between them that is worth naming directly. An EEE manufacturer must test every homogeneous material inside a device against Annex II limits and maintain exemption documentation; a packaging manufacturer producing a rigid box, carton, or label has no RoHS duty at all unless that packaging contains an electronic component, such as an embedded LED or Bluetooth chip.

That means packaging teams can skip RoHS testing entirely in the overwhelming majority of cases, but they cannot skip REACH. The finished box or label is still an article subject to the same 0.1% w/w SVHC screening under REACH, and SCIP notification under the EU Waste Framework Directive, that apply to a plastic connector housing, while the inks, adhesives and coatings used on it are mixtures whose suppliers carry their own REACH duties, such as providing safety data sheets where required.

The practical consequence is that packaging compliance work concentrates entirely on material sourcing and documentation, rather than on laboratory substance testing against a fixed Annex II list. A packaging buyer who understands this difference can direct compliance effort where it actually applies, instead of requesting RoHS test certificates that a print or box supplier has no obligation to provide.

9. How to map packaging components for a compliance review

Mapping a packaging structure for REACH purposes works the same way as mapping a BOM for RoHS: break the finished piece down into every distinct material and screen each one, then check the 0.1% w/w threshold against the article that material ends up in, such as the printed board, the laminate film, the label or a ribbon, not against the ink or adhesive on its own.

A typical rigid gift box might include printed paperboard, a laminate film, an adhesive layer bonding the liner, a foil-stamped logo, and a ribbon or magnetic closure. Each of those is a candidate for individual SVHC screening, since a foil or adhesive can carry a different substance profile than the paperboard itself.

A workable mapping process looks like this:

  • List every distinct material in the finished packaging piece, including inks, coatings, and fasteners.
  • Request a formulation declaration or safety data sheet from the supplier of each material.
  • Cross-check each declared substance against the current Candidate List for SVHC status.
  • Flag any material lacking documentation for lab testing before it goes into production.

Running this mapping exercise once, early in supplier selection, is far less costly than discovering an undocumented adhesive six weeks before a retail launch.

10. How non-compliant packaging affects shelf access and retailer approval

A beauty, spirits, or lifestyle brand that ships packaging with an undeclared SVHC risks more than a regulatory notice. EU retailers increasingly require substance declarations as a condition of listing, and a missing or incomplete declaration can delay or block a product from reaching shelves regardless of how the product itself performs in testing.

Import customs checks can also flag packaging materials, creating delays that ripple into launch timelines and retailer delivery windows. A brand that cannot provide the Article 33 information that retailers and distributors must receive automatically when the goods are supplied risks losing that listing entirely, since large retail buyers treat compliance documentation as a standard procurement gate, not an optional extra.

Beyond the immediate commercial risk, non-compliant packaging damages a brand's standing with the retail partners it depends on for repeat business. A documented, consistent substance declaration process signals the kind of operational reliability that keeps a packaging supplier relationship, and a retail listing, intact over multiple seasons.

11. What to prioritize now, and over the next 90 days

The regulatory direction is toward tighter alignment, not looser rules. Certivo's analysis of upcoming RoHS exemption changes points to ECHA taking over RoHS exemption science, which should make RoHS and REACH decisions more consistent over time, but it also means exemption renewals deserve earlier planning, not less.

For the next 90 days, prioritize three things: SCIP readiness, supplier data collection, and targeted RoHS testing. A workable phasing looks like a BOM audit in weeks one and two, supplier outreach through week six, targeted lab testing through week ten, and documentation plus SCIP preparation in the final two weeks.

— Anthony

12. How Yuan Packaging supports compliant, documented packaging

We build material controls and supplier documentation into every custom packaging order, drawing on extensive experience producing rigid boxes, labels, cartons, and bags for regulated beauty, spirits, and lifestyle brands. Our sourcing favors responsibly documented materials, which gives your compliance team a cleaner paper trail from the first sample round.

If your next packaging run needs documented, compliance-ready materials, review our product range or reach out for a material-declaration template suited to your launch.

FAQ

What is the difference between RoHS and REACH?

RoHS restricts specific hazardous substances inside electrical and electronic equipment, measured at the homogeneous-material level, while REACH governs chemical substances across virtually any article placed on the EU market. A product can comply with RoHS and still carry separate REACH obligations, since the two frameworks assess different things using different thresholds, as ECHA's guidance on restricted substances explains.

Is REACH mandatory in the EU?

Yes, REACH applies to any manufacturer, importer, or distributor placing chemical substances or articles containing them on the EU market, and duties such as Article 33 communication apply automatically once the relevant thresholds are met, with SCIP notification following on the same trigger under the EU Waste Framework Directive. The ECHA candidate list obligations guidance sets out exactly when those duties are triggered.

Is there going to be a REACH revision in 2026?

Regulatory bodies have signaled ongoing alignment work between REACH and RoHS, including a shift toward ECHA handling RoHS exemption science, but specific REACH revision dates and scope should be confirmed directly through ECHA's official guidance rather than secondary sources.

What does "RoHS and REACH compliant" mean?

It means a product meets RoHS Annex II substance limits at the homogeneous-material level and has been screened for REACH SVHCs, with any required Article 33 communications and SCIP notifications completed. Both compliance states need to be verified separately, since passing one does not confirm the other, as explained in IoT Approval's comparison of the two frameworks.

Sources

What is the difference between RoHS and REACH?

RoHS restricts specific hazardous substances inside electrical and electronic equipment, measured at the homogeneous-material level, while REACH governs chemical substances across virtually any article placed on the EU market. A product can comply with RoHS and still carry separate REACH obligations, since the two frameworks assess different things using different thresholds, as ECHA's guidance on restricted substances explains.

Is REACH mandatory in the EU?

Yes, REACH applies to any manufacturer, importer, or distributor placing chemical substances or articles containing them on the EU market, and duties such as Article 33 communication apply automatically once the relevant thresholds are met, with SCIP notification following on the same trigger under the EU Waste Framework Directive. The ECHA candidate list obligations guidance sets out exactly when those duties are triggered.

Is there going to be a REACH revision in 2026?

Regulatory bodies have signaled ongoing alignment work between REACH and RoHS, including a shift toward ECHA handling RoHS exemption science, but specific REACH revision dates and scope should be confirmed directly through ECHA's official guidance rather than secondary sources.

What does "RoHS and REACH compliant" mean?

It means a product meets RoHS Annex II substance limits at the homogeneous-material level and has been screened for REACH SVHCs, with any required Article 33 communications and SCIP notifications completed. Both compliance states need to be verified separately, since passing one does not confirm the other, as explained in IoT Approval's comparison of the two frameworks.