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What are the REACH regulations on non-EU packaging material manufacturers that export to the EU?

October 30, 2007
Question 

Can you clarify the impact of REACH regulations on non-European manufacturers of packaging materials exported to the EU? We've invested some time in studying this but have yet to reach an understanding precisely what impact REACH will have on us in terms of documentation. I've also seen a BBC article claiming that packaging materials are exempt from REACH. At the same time numerous professional organizations are holding seminars to aid packaging manufacturers in dealing with the new legislation. Where does the truth lie?

Answer 

REACH does not apply to finished articles, per se. However, it does apply to the chemical substances used to make those articles. Thus, it can and likely will have an effect on food packaging material manufacturers.

REACH includes rules on the role of distributors and downstream users in the supply chain, especially with respect to how manufacturers, importers, or downstream users should respond to information on identified uses of chemical substances. Ultimately, downstream users of chemicals must apply the risk management measures for dangerous substances that have been identified on the supplier Safety Data Sheets. They have a right to make their use of a substance known to a supplier/manufacturer so that the supplier can identify the use to the authorities and have it covered in the supplier's chemical safety assessment. Alternatively, downstream users can conduct their own chemical safety assessment and report this use to the appropriate chemicals agency. Users of chemicals are advised to communicate with their suppliers to ensure that their uses are covered by registration dossiers of their suppliers. A number of articles on REACH can be found on PackagingLaw.com, including one on the introduction of REACH and a more recent one on the fee structure for REACH.