Label-Makers under EU REACH and EU RoHS

Question Posed:

Would a label-maker be considered in scope of product compliance regulations such as REACH and RoHS?

Answer Provided:

Both laws consider labels differently.

A label has to indirectly meet RoHS substance restriction requirements if affixed to an in-scope product that meets the definition of EEE under the directive.  Labels are in scope of REACH, since they are defined as articles or multiple articles, depending on the complexity of the label itself.

 

**Article contents valid as of 2019-03-18

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