Exporting Packaging to the EU: 4 Categories of Compliance Requirements — REACH / EC 1935/2004 / 94/62/EC / EN 13427 — Printers Most Often Fail on REACH SVHC Thresholds
💡 💡 At a Glance
Core interpretation of the 4 categories of EU packaging regulations: REACH SVHC + EC 1935/2004 food contact + 94/62/EC Packaging Directive + EN 13427 recyclability assessment — printers most often fail on the dual overages of the SVHC 0.1% notification threshold and the 100 ppm combined heavy metals limit.
In May 2026, a customer making organic food packaging for the German market reached out to us. Their exact words were:
"Master, our packaging needs to go on shelves at organic supermarkets in Germany. The printer needs to provide a REACH compliance declaration + EC 1935/2004 food contact test report + a Packaging Directive declaration of conformity. The printer we worked with before gave us a REACH report but no SVHC notification statement, so the German customer rejected it."
It sounds very professional — the customer asked for 3 documents, and the printer only supplied one. But when we opened the customer's sample, the ink was a domestic general offset ink with no SVHC screening performed. This printer didn't fail to do it on purpose — they simply didn't know how to test, or what the threshold was.
For packaging exported to the EU, what is truly difficult isn't production but the fact that 4 categories of regulations apply simultaneously: REACH chemical restrictions, EC 1935/2004 food contact, 94/62/EC Packaging and Packaging Waste, and EN 13427 recyclability assessment — any one item out of compliance, and EU customs detaining the goods or supermarkets pulling them from shelves happens in minutes, and the printer will also be jointly fined.
Category 1: REACH SVHC Notification — 3 Real Cases Where Printers Most Often Fail
REACH is the EU regulation on the Registration, Evaluation, Authorisation and Restriction of Chemicals. The area where printers trip up most is SVHC (Substances of Very High Concern) notification. Printers typically fail REACH for 3 reasons:
Case 1. Ink SVHC exceeds the 0.1% threshold. One printer made food packaging bags for a German customer using a domestic general offset ink containing the phthalate DEHP (a substance on the REACH SVHC list), at a concentration of 0.15% (exceeding the 0.1% notification threshold). German customs spot-checked and judged it non-compliant, and the entire batch was returned.
Case 2. No SVHC screening performed on plastic packaging. One printer made EU plastic food boxes using domestic ABS plastic, but ABS may contain Bisphenol A (added to the SVHC list in 2017). The printer performed no SVHC screening and directly issued a report claiming "REACH compliant," which the German customer's audit caught.
Case 3. SDS Safety Data Sheet is incomplete. REACH requires suppliers to provide an SDS (Safety Data Sheet). One printer only provided an MSDS, not an SDS. The German customer's audit found the SDS missing and judged the printer non-compliant.
Category 2: EC 1935/2004 Food Contact — 4 Types of Material Mismatches Where Printers Most Often Slip
EC 1935/2004 is the EU regulation on food contact materials. Printers most often trip up on this one by mismatching 4 types of materials:
1. Plastic migration test conditions differ. EC 1935/2004's requirements for plastic migration testing reference EU 10/2011 (similar to GB 4806.7 but with differences). One printer used a GB 4806.7 report to cover EU 10/2011, and the German customer judged the report invalid.
2. Paper must comply with BfR recommendations. EU paper-based food contact materials are governed by BfR (German Federal Institute for Risk Assessment) Recommendation XXXVI. One printer used a US FDA standard for the report, and the German customer judged it non-compliant.
3. Metals must comply with EU 1935/2004 + specific metal guidelines. The EU has specific guidelines for metal packaging. One printer made olive oil tin cans for an Italian customer without conducting metal-specific migration testing, and it was judged non-compliant.
4. Ink migration must comply with the Swiss Ordinance. Switzerland has a stricter Swiss Ordinance list for food contact inks. One printer making packaging for a Swiss customer didn't notice this requirement and was judged non-compliant.
Category 3: 94/62/EC Packaging and Packaging Waste — 3 Things Printers Should Confirm Before Sending Samples for Testing
94/62/EC is the EU Packaging and Packaging Waste Directive. The core requirements are the heavy metals total limits + recycling markings. Printers fail in 3 ways:
1. Combined Cd + Pb + Hg + Cr VI exceeds 100 ppm. 94/62/EC explicitly requires that the combined content of cadmium, lead, mercury, and hexavalent chromium in packaging materials must not exceed 100 ppm. One printer used a domestic ink (with lead chrome yellow pigment in the colorant); the ink transferred onto the packaging, and the combined lead and chrome content exceeded 200 ppm, which German customs spot-checked and judged non-compliant.
2. Recycling marks missing or printed wrong. 94/62/EC is paired with EN 17130 recycling marking standard. One printer making EU plastic packaging only printed the triangular chasing-arrows recycling symbol without the number (1–7 indicating the plastic type), and was judged non-compliant.
3. The "Green Dot" mark cannot be printed. The "Green Dot" is a paid mark for Germany's DSD system; printers cannot print it without paying. One printer simply copied the Green Dot from a German designer's artwork directly into their domestic artwork and was caught and judged non-compliant by the German customer.
Category 4: EN 13427 Recyclability Assessment — Printers Only Need This When Taking Eco-Friendly Orders
EN 13427 is the EU standard for packaging recyclability assessment. It is mainly used by EU customer brand owners themselves for assessment; printers only need to provide a material composition declaration and test reports when taking orders. Printers fail in 3 ways:
1. Recyclability claims for composite packaging. One printer made paper-plastic composite packaging (like milk cartons), and the EU customer requested a recyclability assessment. The printer claimed "recyclable," but the EU assessment showed that this paper-plastic composite structure required special separation in Germany's yellow bag/sack paper recycling system, so the brand owner revised the printer's claim to "should be assessed before claiming recyclable."
2. EN 13432 report for biodegradable packaging. EN 13427 is recyclability assessment; EN 13432 is industrial composting certification — the two are different. One printer exporting PLA lunch boxes claimed "compliant with EN 13427" but actually provided an EN 13432 report, which was judged as the wrong type of report.
3. Testing for reusable packaging. EN 13427 also assesses the durability of reusable packaging. One printer making EU reusable transit crates claimed "reusable 50 times" but did not conduct durability testing, and the brand owner revised the advertising copy.
Further Reading
Exporting Packaging to the US: 3 Hurdles — What FDA, Prop 65, and CPSIA Each Cover
FAQ
How is the REACH SVHC 0.1% threshold calculated?
The REACH SVHC threshold of 0.1% (w/w) is calculated by "homogeneous material," not by the entire packaging. For example, if a packaging has three layers — ink layer, plastic layer, paper base layer — the SVHC content of the ink layer is calculated alone; if it does not exceed 0.1%, no notification is required. If the ink layer contains DEHP at 0.15%, even if the average DEHP content of the entire packaging is only 0.05%, the ink layer must still be notified.
What information does the customer need to provide when the printer sends samples for EC 1935/2004 testing?
The printer needs the customer to provide 3 categories of information: 1) Food type (fatty / aqueous / dry / acidic), which determines the simulant; 2) Contact temperature and time (ambient short-term / high-temperature short-term / high-temperature long-term), which determines the test conditions; 3) Contact ratio (packaging area per unit mass of food), which determines the migration calculation. If any of these three is missing, the lab cannot provide an accurate test plan.
How is the 94/62/EC heavy metals 100 ppm total measured?
The 94/62/EC heavy metals 100 ppm total is measured by acid extraction — the packaging material is immersed in 0.07 mol/L hydrochloric acid for 24 hours, simulating extreme contact conditions (such as acidic beverages). Then the content of the four heavy metals — cadmium, lead, mercury, and hexavalent chromium — is measured. One printer used ICP-MS to measure the total content without performing the acid extraction, and was judged to have used the wrong test method.
The customer says "all our previous suppliers did one report" — can the new printer use it directly?
No. Check the five essentials of the report: 1) Is the product name the same? 2) Is the formula/ink the same? 3) Is the report date within 1 year (the REACH SVHC list is updated twice a year)? 4) Is the testing body on the EU-approved list (Notified Body number)? 5) Does it include a Compliance Letter? If any of these five is missing, the EU customer's audit will judge the printer non-compliant.
When a printer takes EU orders, should testing fees be listed separately in the quote?
It is recommended to list them separately. EU packaging testing fees are quoted as a "regulation × material" combination: REACH SVHC screening RMB 5,000–15,000 per material, EC 1935/2004 migration RMB 10,000–30,000 per material, 94/62/EC heavy metals total RMB 3,000–8,000 per material. One package involves 3 categories of regulations, so total testing fees are RMB 20,000–50,000. If the printer's quote does not list this, once the customer receives the goods and discovers they need to spend this much extra, the purchasing agent will be scolded by the boss.
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