Packaging is part of the EU REACH Regulation, but where is the line? Does it include all shipping labels, such as a “fragile” sticker?
The Guidance on Substances in Articles provides the following:
“Substances, mixtures and articles can be contained inside packaging, such as a carton, a plastic wrapping or a tin can. In principle, the main functions of packaging may be containment and delivery of e.g. substances or mixtures, protection for the product packaged, and presentation or aesthetic purpose. In many cases, it also contributes to the safety of humans and the environment during handling or use of the content. Therefore, packaging is to be considered as an article because its shape, surface or design is more important than its chemical composition for the above mentioned functions. The packaging is not a part of the substance, mixture or article being packaged. It is therefore to be considered as a separate article under REACH and the same requirements apply to it as for any other article."
REACH requirements thus apply to all packaging, including labels. If the packaging is meant to be kept with the product (for instance, a storage case for a tool) then that packaging material should be included in the product's REACH declaration. If the packaging is not meant to be kept with the product, it may need to be provided as its own separate declaration.
Article current as of 2020-07-10.