EU REACH Certification for Packaging Materials: How to Check the SVHC Candidate List + 5-Step Practical Guide

Earlier this year, a client who has been in foreign trade for 8 years came to me. She said: "I've been doing exports for over ten years and never knew that phthalates in ink are also SVHC. This time, I got a rejection from a German client."

I pulled up her test report and took a look—the issue was in the laminating adhesive—DEHP content of 0.12%, just right at the edge of the SVHC threshold of 0.1%. This is a typical case of "missing a narrow win."

But the more I deal with this kind of issue, the more I feel that SVHC is not an "unfathomable regulation"—but rather a practical skill of "knowing how to use the database." This article explains how to use the ECHA database + a 5-step self-inspection process + 3 supplier screening forms to turn REACH compliance into a routine factory operation.

Step 1: Open the ECHA Database—Simpler Than You Think

The SVHC database of ECHA (European Chemicals Agency) is publicly available at the following link:

echa.europa.eu/candidate-list-table

Once you open it, you will see a long table containing all SVHC substances: CAS number, EC number, Chinese and English names, date of inclusion, and threshold definition (default 0.1% w/w). As of the latest version in January 2024, the SVHC list includes 240 substances.

Usage tip: You can switch languages via the top-right corner of the page, but the Chinese translations of substance names are not accurate. It is recommended to search by CAS number or EC number. CAS numbers are internationally recognized—any test report provided by a material supplier will include a CAS number.

LeXiang factory experience: It is recommended to bookmark this webpage in your browser's favorites bar and check it every time new materials arrive from a supplier.

Step 2: Identify what materials are in your packaging

Many customers go straight to the database, but forget what materials are actually in their packaging. The REACH checklist for packaging materials (used internally at LeXiang):

• Outer liner/inner liner—paper itself generally has low SVHC risk, but surface coatings/dyes may contain them
• Inks—UV inks, spot-color inks, and metallic inks are high-risk points
• Adhesives—white latex, hot-melt adhesive, and starch-based adhesive may all contain phthalates
• Lamination film—BOPP/PVC lamination film itself has low risk, but the adhesive layer may contain them
• UV varnish/spot UV—photoinitiators are potential migration sources
• Hot stamping foil—metallic hot stamping foil is usually low risk, but pigmented foil needs to be checked

Check each component separately—don't check the entire gift box as a single component. This is the most common mistake beginners make. A gift box has 5 components, and each component requires checking 240 SVHCs, so the workload = 5 × 240 = 1,200 queries. That's why the next step is using tools to batch-check.

Step 3: Batch Comparison — 3 Practical Tools

Checking SVHC one by one is unrealistic. LeXiang uses a combination of 3 tools in routine work:

Tool 1: RoHS/REACH Test Reports Provided by Suppliers

Every supplier (ink manufacturer / adhesive manufacturer / paper mill) should provide a declaration of conformity or a third-party test report. LeXiang requires all suppliers to sign a REACH compliance declaration and archives this document. If a supplier does not provide one, do not cooperate directly—this is the bottom line.

Tool 2: ECHA Database + Excel Filtering

Download the ECHA SVHC list as an Excel file (CSV format), filter using the CAS number column, and place the CAS numbers from the test reports provided by all component suppliers into this column for comparison. If any CAS number is flagged in red on the SVHC list, an individual assessment is required.

Tool 3: Third-Party REACH Testing Institutions

If the customer is uncertain about the results, third-party testing can be commissioned (the most authoritative institutions in the EU are SGS and TÜV). A single-item test costs 3,000-8,000 RMB, while a full set costs 80,000-150,000 RMB. During reviews by German customers, a third-party report is more persuasive than a supplier's self-declaration.

Step 4: Threshold Determination—The Practical Meaning of 0.1% w/w

The SVHC threshold is 0.1% by weight (w/w). This figure means the weight of the SVHC substance as a proportion of the total weight of the finished packaging.

In practice, there are two scenarios:

• Whole-box calculation—SVHC weight ÷ total box weight < 0.1% → compliant
• Component calculation—SVHC weight ÷ weight of the component containing it < 0.1% → compliant (but must be disclosed in the supply chain information)

LeXiang factory experience: component calculation is the EU "convention"—because many SVHCs serve functional purposes in inks/adhesives and cannot be fully substituted. However, a supply chain information sheet (SDS) must be provided to the customer so they are aware.

The first scenario (whole-box calculation) is extremely strict and barely allows any SVHC presence. German customers typically use this standard; French and Italian customers more often use component calculation.

Applied to the export customer case mentioned earlier: the lamination adhesive contains 0.12% DEHP. If calculated on a whole-box basis (adhesive accounts for only 0.5% of box weight), the whole-box DEHP proportion is 0.0006%, far below 0.1%. But the German customer's component calculation (DEHP 0.12% ÷ adhesive 100% = 0.12%) results in an immediate non-compliance finding. This is the German customer's conservative approach, but it complies with the regulations.

Step 5: Three Options for Handling Exceedances

After the check, there are typically three outcomes:

Outcome A: Fully Compliant → Keep the supplier and continue production. Conduct a review every 12-18 months.

Outcome B: Threshold Edge (0.08-0.12%) → Don't gamble. Switch to another supplier or a different process. Switch to food-grade/low-SVHC inks and adhesives; the price difference is 30-50%, but it can resolve the issue completely.

Outcome C: Clear Exceedance (>0.12%) → The process or materials must be changed. If the product has already been shipped, immediately notify the brand owner and end customers and initiate a recall or removal process.

3 Supplier Screening Forms Used by LeXiang Factory

The following 3 forms are the daily REACH supplier screening templates used by LeXiang (desensitized version):

Form 1: Ink Supplier Screening Form (12 mandatory fields)

Includes ink model, UV/non-UV, migration test report number, CAS number list, SVHC substance list (240-item checklist), and supplier compliance statement with signature/seal.

Form 2: Adhesive/UV Supplier Screening Form (10 mandatory fields)

Adhesive type (white latex/hot-melt adhesive/starch-based adhesive), free formaldehyde testing, phthalate testing, and compliance with EN 71-3.

Form 3: Paper/Laminating Supplier Screening Form (8 mandatory fields)

Paper grammage, origin, dye type, PVC/PET/BOPP material declaration, and whether chlorine bleaching is used.

These 3 forms were developed through lessons learned by LeXiang from 2018-2025—initially we only had Form 1, and later discovered that adhesives and paper also carry SVHC risks, so we gradually completed the set. It is recommended that factories also establish similar 3 forms, as using forms is far more reliable than relying on memory.

Things to Avoid

After covering the positive points, here are a few "things to avoid":

Do not rely on a single supplier's commitment. No ink or adhesive manufacturer dares to guarantee 100% SVHC-free—because regulations are updated quickly, and compliance last year does not mean compliance this year.

Do not put all your eggs in the "test report" basket. A test report from 2023 may no longer be sufficient after the SVHC list expands from 224 to 240 entries in 2025.

Do not overlook packaging instructions. Some brand owners not only require the packaging materials to be REACH-compliant, but also require the REACH mark or a compliance declaration to be printed on the packaging—this is another topic entirely.

REACH compliance is not a one-time action; it is ongoing supply chain management. A comprehensive review once a year saves far more money than testing every small batch.

Further Reading

• What international certifications are required for exporting packaging materials
• What is FSC certification? Why do packaging companies need it?
• What certifications and testing are required for food packaging
• FDA food contact material certification 21 CFR practical guide
• What are the common certifications in the packaging industry