If you sell packaging tape in the European Union, you need to comply with multiple regulations simultaneously. The three most important are REACH, RoHS, and the new PPWR. They look similar at first glance — all deal with hazardous substances and product safety — but they address fundamentally different concerns, apply through different legal mechanisms, and carry different compliance obligations.
Understanding the differences is not just an academic exercise. It helps you choose the right tape for your market, prepare the right documentation for customs and audits, and avoid the costly mistake of assuming that compliance with one regulation automatically means compliance with all of them. This guide compares the three regulations head-to-head and shows how a smart testing strategy can satisfy all three with a single set of documents.
The Three Regulations at a Glance
Before diving into details, here is a high-level comparison of the three regulations most relevant to packaging tape sold in the EU:
- REACH (EC 1907/2006) — Chemical safety. Restricts hazardous substances in all products placed on the EU market. Managed by the European Chemicals Agency (ECHA). Key mechanism: the SVHC Candidate List, currently comprising 253 substances.
- RoHS (2011/65/EU) — Hazardous substances in electrical and electronic equipment. Restricts 10 specific substances in electronics — and the packaging that contains them. Focuses on heavy metals and phthalates.
- PPWR (EU 2025/40) — Packaging design and waste management. The new Packaging and Packaging Waste Regulation. Covers recyclability, heavy metals, PFAS, packaging minimization, and Extended Producer Responsibility (EPR). Applies to all packaging placed on the EU market.
Each regulation has a different legal form, a different enforcement authority, and a different primary concern. But they overlap in practice — and a well-prepared supplier can satisfy all three with coordinated testing.
REACH: Chemical Safety Across All Products
REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemicals. It is Regulation (EC) No 1907/2006, and it is one of the most comprehensive chemical safety frameworks in the world. It is managed by the European Chemicals Agency (ECHA), headquartered in Helsinki.
REACH applies to virtually all chemical substances placed on the EU market — whether manufactured in the EU or imported. That includes raw materials, industrial chemicals, and the chemical substances contained in finished products like packaging tape.
The SVHC Candidate List
The core compliance mechanism under REACH is the Substances of Very High Concern (SVHC) Candidate List. This list is updated approximately every six months and currently contains 253 substances (as of 2026). Substances are added to the list based on hazards such as carcinogenicity, mutagenicity, reproductive toxicity, persistence in the environment (PBT), and endocrine disruption.
The key obligation: if a product contains an SVHC at a concentration above 0.1% by weight (w/w), the supplier must provide sufficient information to the recipient — and to consumers on request — to allow the safe use of the product. Substances on the SVHC list can later be moved to the Authorisation List (Annex XIV), which restricts their use entirely unless specific authorisation is granted.
What REACH Means for Packaging Tape
For packaging tape, the main REACH concerns are:
- Phthalates in PVC tape. PVC (polyvinyl chloride) tape often relies on phthalate plasticizers for flexibility. Several phthalates — including DEHP, DBP, BBP, and DIBP — are on the SVHC list. PVC tape is the highest-risk category for REACH violations.
- Heavy metals in inks and dyes. Colored and printed tapes may contain heavy-metal-based pigments. Lead, cadmium, and other SVHC-listed metals can appear in low-quality ink formulations.
- SVHC substances in adhesives. Certain adhesive additives, tackifiers, and resin components may contain SVHC substances. Even solvent residues from the manufacturing process can be a concern.
Verification requires third-party laboratory testing for all 253 SVHC substances. Generic statements like "REACH compliant" without a supporting test report are insufficient for serious buyers and EU enforcement authorities.
Our status: Guangfeng Packaging's kraft paper tape has been tested by TUV Rheinland, with all 253 SVHC substances reported as non-detected. Full test reports are available on request.
RoHS: Hazardous Substances in Electronics (and Their Packaging)
RoHS stands for Restriction of Hazardous Substances. It originated as Directive 2002/95/EC and was recast as Directive 2011/65/EU, with subsequent amendments. Unlike REACH, which covers all products, RoHS specifically targets electrical and electronic equipment (EEE).
The 10 Restricted Substances
RoHS restricts the use of 10 substances in EEE above specified concentration limits (0.1% by weight, except cadmium at 0.01%):
- Lead (Pb)
- Mercury (Hg)
- Cadmium (Cd)
- Hexavalent chromium (Cr6+)
- Polybrominated biphenyls (PBB)
- Polybrominated diphenyl ethers (PBDE)
- Di(2-ethylhexyl) phthalate (DEHP)
- Butyl benzyl phthalate (BBP)
- Dibutyl phthalate (DBP)
- Diisobutyl phthalate (DIBP)
The first six are the original RoHS substances (heavy metals and brominated flame retardants). The four phthalates were added by Delegated Directive (EU) 2015/863 and have been restricted since July 22, 2019.
What RoHS Means for Packaging Tape
RoHS applies directly to electronic products, but packaging of electronic products is also relevant. If your packaging tape is used to seal cartons containing electronic goods — smartphones, computers, appliances, components — that tape should be RoHS-compliant. Contaminants from packaging can transfer to products during shipping and storage, and responsible electronics brands require RoHS compliance throughout their entire supply chain, including packaging materials.
For packaging tape, the main RoHS risk areas are the same as for REACH: heavy metals in pigments (especially lead and cadmium), hexavalent chromium in coatings, and phthalates in PVC formulations. The overlap with REACH's SVHC list is significant — the four phthalates restricted under RoHS are also on the REACH SVHC Candidate List.
Our status: All 10 RoHS-restricted substances are non-detected in our kraft paper tape, confirmed by independent laboratory testing.
PPWR: Packaging Lifecycle Management
PPWR — the Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40 — is the newest and most impactful regulation for packaging tape specifically. It entered into force on February 11, 2025, with general enforcement beginning August 12, 2026. Unlike the old Packaging Directive (94/62/EC) it replaces, the PPWR is a Regulation, meaning it applies directly in all EU member states without national transposition.
PPWR takes a lifecycle approach to packaging. Its key provisions include:
- Recyclability grading (A/B/C). From January 1, 2030, all packaging must be recyclable, assessed against Design for Recycling criteria. Grade A is the best; below Grade C is banned. By 2038, only Grade A and B will be permitted.
- Heavy metals limit. The combined concentration of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg.
- PFAS restrictions. Per- and polyfluoroalkyl substances are restricted in food-contact packaging from August 2026.
- EPR registration. Extended Producer Responsibility requires registration in each EU country where packaging is placed on the market.
- Packaging minimization. Packaging must be designed to minimize weight and volume while maintaining performance.
- Material labeling. From August 2028, standardized labels indicating material composition and recyclability will be required.
What PPWR Means for Packaging Tape
The recyclability requirement is the single biggest impact of PPWR on packaging tape. The grading system assesses how well packaging material flows through real-world recycling infrastructure:
- Paper-based tape (kraft paper tape) = Grade A or B. Paper has the highest recycling rate of any packaging material in the EU (over 70%), with established collection and processing infrastructure in every member state. Kraft paper tape can be recycled together with cardboard cartons.
- Plastic tape (BOPP/OPP) = Grade C. Polypropylene is technically recyclable, but post-consumer adhesive tape is almost never recycled in practice due to adhesive contamination and small-format sorting challenges. BOPP tape will be banned from 2038.
- PVC tape = below Grade C. Chlorinated polymer with no recycling infrastructure. Likely banned from 2030.
EPR registration is also a significant new obligation. If you sell packaged goods in multiple EU countries, you must register for EPR in each country — there is no single EU-wide EPR number.
Key Differences Explained
While REACH, RoHS, and PPWR all touch on hazardous substances, they are distinct regulations with different scopes, legal forms, and primary concerns. Here is how they compare across key dimensions:
Scope
REACH covers chemicals in all products — not just packaging, not just electronics, but any product placed on the EU market. RoHS is narrower: it covers electrical and electronic equipment and their packaging. PPWR covers all packaging — regardless of what it contains or where it comes from.
What They Restrict
REACH restricts SVHC chemicals — a dynamic list of 253 substances that grows over time. RoHS restricts 10 specific substances — heavy metals, brominated flame retardants, and phthalates. PPWR restricts heavy metals (combined limit), PFAS in food-contact packaging, and non-recyclable packaging design.
Legal Form
REACH is a Regulation — directly applicable in all EU member states. RoHS is a Directive — it requires national transposition, meaning implementation details can vary slightly between countries. PPWR is a Regulation — directly applicable, eliminating the interpretation gaps that existed under the old Packaging Directive.
Primary Concern
REACH is about human and environmental health — ensuring that hazardous chemicals are identified, assessed, and controlled. RoHS is about electronics safety — preventing hazardous substances from entering electronic products and their packaging. PPWR is about the circular economy and waste reduction — ensuring that packaging is designed to be recyclable, minimal, and properly managed at end-of-life.
For Packaging Tape Specifically
REACH requires that the tape contain no SVHC chemicals above 0.1%. RoHS requires that the tape contain none of the 10 restricted substances above their thresholds — especially relevant when tape is used on electronics packaging. PPWR requires that the tape be recyclable, free from excess heavy metals, and properly registered under EPR.
REACH and RoHS ask: "What's in the tape?" PPWR asks: "What happens to the tape after it's used?" Both questions matter — and you need to answer both.
Overlap: One Test Report, Multiple Regulations
The good news is that while the three regulations are distinct, their testing requirements overlap significantly. A smart testing strategy can demonstrate compliance with all three simultaneously, saving both time and cost. Here's how the overlaps work:
- Heavy metals test (Pb, Cd, Hg, Cr6+) → Satisfies PPWR's 100 mg/kg combined limit AND covers four of the 10 RoHS restricted substances.
- SVHC test (253 substances) → Satisfies REACH requirements comprehensively. Also overlaps with RoHS phthalates (DEHP, BBP, DBP, DIBP are all on the SVHC list).
- Phthalate test → Satisfies both RoHS (4 restricted phthalates) AND REACH (phthalates on the SVHC list).
- Material declaration → Supports PPWR recyclability assessment and provides the basis for EPR reporting.
Our approach: Guangfeng Packaging's kraft paper tape is tested by TUV Rheinland, an internationally accredited laboratory. A single comprehensive test program covers REACH (all 253 SVHC substances) and RoHS (all 10 restricted substances) simultaneously. Because the RoHS heavy metals test already measures lead, cadmium, mercury, and hexavalent chromium — and all are non-detected — the PPWR heavy metal limit of 100 mg/kg is automatically satisfied. No separate PPWR chemical test is needed.
A well-designed test report from an accredited laboratory can demonstrate compliance with REACH, RoHS, and PPWR simultaneously — saving time and cost.
This is the practical advantage of working with a supplier that understands the regulatory landscape. Instead of commissioning three separate tests at three different labs, you receive one coherent documentation package that addresses every applicable regulation.
Which Regulation Matters Most for Packaging Tape?
All three regulations are important, but PPWR is the most impactful for packaging tape specifically. Here's why:
REACH and RoHS are about what's in the tape — the chemical composition. A reputable manufacturer using quality raw materials can achieve compliance relatively straightforwardly. Kraft paper tape made from natural wood pulp and hot-melt adhesive is inherently low-risk for both regulations.
PPWR is about what happens after the tape is used — the end-of-life outcome. This is where material choice becomes decisive. A tape can be chemically safe but environmentally problematic. Consider these scenarios:
- A tape can be REACH/RoHS compliant but fail PPWR. Example: BOPP tape with safe, non-hazardous chemicals passes REACH and RoHS — but its poor recyclability means it will fail PPWR's 2030 and 2038 requirements.
- A tape can be PPWR-compliant but fail REACH. Example: A recyclable paper tape that uses an adhesive containing an SVHC substance above 0.1% would pass PPWR's recyclability criteria but fail REACH.
- The ideal: a tape that passes all three. Kraft paper tape from a certified manufacturer — recyclable (PPWR Grade A/B), free from all 253 SVHC substances (REACH), and free from all 10 RoHS restricted substances — is the comprehensive solution.
This is why material selection matters more than ever. A plastic tape that is chemically safe today may be environmentally non-compliant tomorrow. A paper tape that is recyclable today but uses non-compliant adhesives is equally problematic. The only robust solution is a tape that is both chemically safe and recyclable — verified by accredited testing.
Checklist: Compliance Documents You Need
To demonstrate full compliance across all three regulations, you should have the following documents from your tape supplier. These are the documents that EU customs authorities, market surveillance agencies, and your own customers may request:
- REACH SVHC test report — Testing for all 253 substances on the current SVHC Candidate List, performed by an accredited laboratory. Must show concentrations or "non-detected" for each substance.
- RoHS test report — Testing for all 10 restricted substances (Pb, Hg, Cd, Cr6+, PBB, PBDE, DEHP, BBP, DBP, DIBP), with measured values below the regulatory thresholds.
- MSDS (Material Safety Data Sheet) — A comprehensive document detailing the material composition, hazard identification, handling, storage, and disposal information for the tape product.
- Material declaration — A formal statement of the tape's material composition (substrate, adhesive, any coatings or inks), supporting PPWR recyclability assessment and EPR reporting.
- Recyclability assessment — For PPWR compliance, an assessment of the tape's recyclability against Design for Recycling criteria. Note: the formal DfR criteria are expected to be finalized by August 2028, but early assessment based on material type is valuable.
- EPR registration — Registration with the relevant Extended Producer Responsibility scheme in each EU country where you place packaging on the market. This is your responsibility as the importer/seller, not the supplier's, but your supplier's documentation supports your reporting.
If your current supplier cannot provide the first four documents, that is a significant compliance gap. REACH and RoHS test reports from an accredited lab are the baseline for credible compliance — not optional extras.
Conclusion
Navigating three EU regulations simultaneously — REACH, RoHS, and PPWR — sounds complex. But the complexity dissolves when you choose the right product from the right supplier. Kraft paper tape from a certified manufacturer simplifies everything: one product, one set of test reports, and full compliance across all three regulatory frameworks.
REACH compliance means your tape contains no hazardous SVHC chemicals. RoHS compliance means it is free from the 10 restricted heavy metals and phthalates. PPWR compliance means it is recyclable, low in heavy metals, and aligned with the EU's circular economy ambitions. Kraft paper tape — made from natural wood pulp, tested by accredited laboratories, and recyclable in existing paper streams — satisfies all three requirements in a single product.
The alternative — managing different tape types for different markets, chasing missing test reports, and worrying about 2030 and 2038 recyclability deadlines — is more expensive, more complex, and more risky. The simplest path to multi-regulation compliance is to work with a supplier who has already done the testing, already has the documentation, and already understands the regulatory landscape.
At Guangfeng Packaging, we provide kraft paper tape backed by TUV Rheinland REACH and RoHS testing, with full documentation ready for your compliance file. Learn more about our quality and testing, explore our PPWR compliance resources, or contact us for a quote with full compliance documentation included.