REACH Guidelines for PP Disposable Food Containers with Lids Exported to the EU
author: Iris
2025-11-19
I. Overview of REACH Regulation and Classification of Lunch Box Products
1.1 Basic Framework and Requirements of REACH Regulation
The REACH Regulation (EC 1907/2006) is the EU's chemical regulatory system, officially titled "Registration, Evaluation, Authorisation and Restriction of Chemicals," which came into effect on June 1, 2007. The core objective of this regulation is to ensure a high level of protection for human health and the environment while maintaining the free movement of goods and services within the EU internal market.
The REACH Regulation classifies products into three main categories: Substances, Mixtures, and Articles. Substances refer to naturally occurring or artificially produced chemical elements and their compounds; mixtures refer to combinations or solutions of two or more substances; and articles refer to objects that have been given a specific shape, surface, or design during the manufacturing process, which determines their function to a greater extent than their chemical composition.
For plastic products, the REACH regulation mainly focuses on the following aspects:
- Registration Requirements: Chemical substances with an annual production or import volume exceeding 1 tonne must be registered. Companies need to submit a registration dossier to the European Chemicals Agency (ECHA), including toxicity data, exposure scenarios, and risk management measures.
- Assessment Mechanism: ECHA assesses registered substances, including dossier assessment and substance assessment, to confirm the completeness and compliance of the information provided by the company.
- Authorization Procedure: For Substances of Very High Concern (SVHCs), authorization must be applied for if continued use is required. The Authorized List (Annex XIV) currently contains 126 substances.
- Restrictive Measures: The Restricted List (Annex XVII) contains 71 restrictive clauses, specifying restrictions on the use of certain substances in specific products.
1.2 Product Classification and Definition of PP Material Food Containers
Disposable PP material food containers are explicitly classified as "Articles" under the REACH regulation. According to the REACH regulation, disposable food containers with lids are defined as containers used to hold food such as rice and soup, typically disposable products for single use. These products are given specific shapes and designs during the manufacturing process, and their functionality is primarily determined by their physical form, not their chemical composition.
- PP (polypropylene) food containers have the following characteristics: non-toxic and odorless, meeting food-grade standards; temperature resistance ranging from -6°C to 120°C, with some modified PP able to withstand -18°C to 110°C; and the only plastic container that can be microwaved, with a melting point as high as 167°C. These properties make PP an ideal material for making disposable food containers.
- The coating materials for food containers typically include: non-stick coatings (such as polytetrafluoroethylene, PTFE), barrier coatings (to prevent liquid penetration), and printing inks. Although these coatings are relatively thin, they still need to be evaluated as independent homogeneous materials under the REACH regulation.
1.3 Special Regulatory Requirements for Food Contact Materials
Food contact materials, including disposable food containers with lids, must comply not only with REACH regulations but also with the EU Food Contact Materials Regulation (EC) No 10/2011. This means Chinese take-out containers face dual regulatory oversight, making compliance requirements more stringent.
According to EC No 10/2011, plastic food contact materials must meet the following basic requirements:
- Safety Requirements: The material must not migrate its components into food, and the migration amount must not endanger human health, cause unacceptable changes in food composition, or reduce the sensory characteristics of the food.
- Authorized Substances List: Only substances listed in the "Union List" can be used to manufacture plastic food contact materials. The list contains 885 authorized substances, including monomers, additives, polymer production aids, and macromolecules produced by microbial fermentation.
- Specific Migration Limits: Migration limits are set for specific substances, such as 0.6 mg/kg for bisphenol A (BPA) and 0.5 mg/kg for lead.
- Overall Migration Limit: The overall migration limit for general materials is 60 mg/kg (food).
It is important to note that the REACH regulation overlaps with food contact materials regulations in some aspects. For example, bisphenol A (BPA) is listed in both the REACH SVHC list and is subject to strict restrictions under food contact materials regulations. On December 19, 2024, the European Commission formally adopted a ban on BPA in food contact materials, which came into effect on January 20, 2025.
II. Analysis of REACH Testing Requirements
2.1 Legal Basis for REACH Testing
According to the REACH regulation, PP Chinese take-out containers exported to the EU must be tested, primarily based on the following legal provisions:
- Article 3 (Definitions): This article clarifies the definitions of substances, mixtures, and articles; disposable food containers with lids fall under the category of "articles."
- Article 7 (Registration and Notification of Substances in Articles): Notification is required when an article contains SVHC substances and meets specific conditions.
- Article 33 (Information Transmission Obligation): When the SVHC content in an article exceeds 0.1%, the supplier must provide relevant information to customers and consumers.
- Annex XVII (List of Restricted Substances): This list specifies substances prohibited or restricted from use in the EU market, and food containers must comply with the relevant restrictions.
- REACH regulations require disposable food containers with lids to meet two main testing requirements:
- SVHC (Substances of Very High Concern) Testing: Testing whether the food container contains more than 0.1% of SVHC substances.
- Restricted Substance Testing: Testing whether the food container contains substances restricted from use in Annex XVII.
2.2 Detailed Explanation of SVHC List Requirements
2.2.1 Latest Version and Update Mechanism of the SVHC List
As of November 2025, the SVHC Candidate List has been updated to its 35th batch, containing a total of 251 substances. The most recent update was on November 5, 2025, when the European Chemicals Agency (ECHA) officially added decabromodiphenyl ethane (DBDPE) to the SVHC list.
The SVHC list update mechanism is as follows:
- Update frequency: ECHA typically updates the SVHC list twice a year, in June and December.
- Update procedure: The addition of new substances requires public consultation and review by member state committees.
- Substance types: SVHC substances mainly include CMR 1A/1B substances (carcinogenic, mutagenic, reproductive toxicity), PBT substances (persistent, bioaccumulative, toxic), vPvB substances (highly persistent, highly bioaccumulative), and substances of equivalent concern.
Companies must closely monitor SVHC list updates, as once a new substance is added, companies have only six months to fulfill their notification obligations.
2.2.2 Identification of SVHC Substances Related to Lunch Containers
Based on the material characteristics of lunch containers, the following categories of SVHC substances require special attention:
1. Phthalates
Phthalates are a major component of plasticizers used to increase the flexibility of plastics. Phthalates that may be present in lunch containers include:
- Di(2-ethylhexyl) phthalate (DEHP)
- Butyl benzyl phthalate (BBP)
- Dibutyl phthalate (DBP)
- Diisobutyl phthalate (DIBP)
Studies have shown that the detection rate of phthalates is very high in commercially available PP plastic lunch containers: DEP (100%), DIBP (100%), DBP (78%), DEHP (78%), DPhP (92%), and DNOP (85%). These substances can migrate into food through contact with plastic lunch containers.
2. Bisphenols
BPA (Bisphenol A) is listed in the SVHC list due to its endocrine-disrupting properties. In addition to BPA, the following should also be noted:
- Bisphenol S (BPS)
- Bisphenol F (BPF)
- Bisphenol AF (BPAF)
These substances are commonly used in the production of polycarbonate plastics and epoxy resins and may be present in the coatings or additives of disposable food containers with lids.
3. Heavy Metals and Their Compounds
Heavy metals may originate from colorants, stabilizers, etc., in food containers:
- Lead compounds (such as lead chromate, molybdenum chromium red, lead chromium yellow)
- Cadmium compounds
- Mercury compounds
- Hexavalent chromium
4. Flame Retardants
DBDPE (decabromodiphenyl ethane), added in November 2025, is a commonly used flame retardant widely used in plastics, coatings, inks, and other fields. In addition, the following should be noted:
- Hexabromocyclododecane (HBCDD)
- Short-chain chlorinated paraffins (SCCPs)
5. Other related substances
Polycyclic aromatic hydrocarbons (PAHs):
- May originate from recycled plastics or carbon black fillers
- Formaldehyde and formaldehyde releasers: May be present in some coatings or adhesives
- Azo dyes: Used for printing patterns on Chinese take-out containers
2.2.3 SVHC Content Limits and Notification Obligations
According to the REACH Regulation, the notification obligations for SVHCs fall into two categories:
Information Transmission Obligation (Article 33)
When the content of any SVHC in an article exceeds 0.1% (by weight), the supplier must provide its customers with "sufficient information to ensure safe use," including at least the name of the substance.
At the request of consumers, the supplier must provide the relevant information free of charge within 45 days.
ECHA Notification Obligation (Article 7 (2))
When the content of an SVHC in an article exceeds 0.1%, and the total amount of that SVHC in the article exceeds 1 tonne/year (calculated by the manufacturer or importer), the supplier must notify ECHA within 6 months of the substance being added to the SVHC list.
It is particularly important to note that, according to the ruling of the European Court of Justice (CJEU) in case C-106/14, the 0.1% threshold applies to each individual component in a complex product and cannot be averaged across the entire product.
2.3 Requirements for Restricted Substances in Annex XVII of REACH
2.3.1 Overview of the List of Restricted Substances in Annex XVII of REACH
Annex XVII of REACH contains a list of substances prohibited or restricted from use in the EU market, comprising 71 restrictions as of November 2025. These restrictions cover a wide range of products and substances, with the main ones related to disposable food containers with lids being:
- Item 23 - Cadmium and its compounds: Limit of 0.01% (100 ppm)
- Item 27 - Lead and its compounds: Limit of 0.05% (500 ppm)
- Item 51 - Phthalate: DEHP, DBP, BBP, and DIBP are limited to 0.1% in plasticized materials
- Item 63 - Lead in PVC: From November 29, 2024, the lead content in PVC materials must not exceed 0.1%
- Item 77 - Formaldehyde: Effective August 6, 2026, requiring control of formaldehyde emissions
2.3.2 Key Restricted Substances Related to Food Containers
1. Phthalate (Item 51)
REACH Annex XVII Item 51 The restrictions on phthalates have undergone several revisions, and the current requirements are as follows: Toys and childcare products: The content of any one or the total amount of the four phthalates DEHP, DBP, BBP, and DIBP must not exceed 0.1% (effective July 7, 2020). Other articles: The content of any one or the total amount of the four phthalates DEHP, DBP, BBP, and DIBP must not exceed 0.1% (effective July 7, 2020).
It is worth noting that food contact materials (within the scope of Regulation (EC) No 1935/2004 or (EU) No 10/2011) are included in the exemption list. However, this does not mean that disposable food containers with lids are unrestricted, as they must still comply with the relevant requirements of the food contact materials regulation.
2. Heavy Metals (Items 23, 27, etc.)
Heavy metal restrictions apply to all items. Heavy metals of concern in lunchboxes include:
- Cadmium (Cd): Limit of 0.01% (100 ppm)
- Lead (Pb): Limit of 0.05% (500 ppm)
- Mercury (Hg): Limit of 0.01% (100 ppm)
- Hexavalent Chromium (CrVI): Limit of 0.1% (1000 ppm)
These heavy metals may originate from colorants, stabilizers, or recycled materials in the eco-friendly take-out containers.
3. Lead in PVC (Amendment to Item 63)
On November 29, 2024, the EU made a significant amendment to Item 63 of Annex XVII of REACH. The new regulation requires:
The lead content in PVC materials must not exceed 0.1% (by weight of PVC).
This applies to all newly manufactured and imported PVC products, including those containing recycled materials.
There are transitional periods for certain applications:
Products containing recycled flexible PVC are exempt until May 28, 2025; certain products containing recycled rigid PVC are exempt until May 28, 2033 (lead content must be less than 1.5%).
Although disposable food containers with lids are primarily made of PP, if they contain PVC components (such as certain coatings or fittings), they must comply with this requirement.
4. Formaldehyde (Item 77)
On July 17, 2023, the EU added Item 77, a restriction on formaldehyde, which will come into effect on August 6, 2026:
- Furniture and wood products: Formaldehyde emission ≤ 0.062 mg/m³
- Other items: Formaldehyde emission ≤ 0.080 mg/m³
- Test conditions: Temperature (23±0.5)℃, Relative humidity (45±3)%, Air exchange rate (1±0.05) h⁻¹
If the coating or adhesive of the food container contains formaldehyde or formaldehyde-releasing agents, the formaldehyde emission must meet the above requirements.
5. Other Relevant Restrictions
- Short-chain chlorinated paraffins (SCCPs): Restriction 45, content must not exceed 0.15% (1500 ppm)
- Polycyclic aromatic hydrocarbons (PAHs): Some PAHs are restricted in plastics that come into prolonged contact with skin.
- Azo dyes: Restriction 43, some azo dyes are prohibited for use in products that may come into contact with skin.
III. Special Testing Requirements for Food Container Coating Materials
3.1 REACH Compliance Requirements for Coating Materials
As functional materials, food container coatings require special evaluation under REACH regulations. Coatings may include anti-stick coatings, barrier coatings, printing inks, etc. Although these coatings are usually thin, they are considered independent homogeneous materials under the regulations and require separate testing.
The REACH compliance requirements for coating materials mainly include:
- Substance Compliance: All chemicals used in the coating must comply with REACH regulations and must not contain prohibited substances.
- SVHC Content: The SVHC content in the coating must not exceed 0.1%.
- Restricted Substances: Must comply with the relevant restrictions in Annex XVII.
- REACH Registration Number: If the coating contains substances requiring registration, a valid REACH registration number must be provided.
3.2 Risk Assessment of Common Chemicals in Coatings
Based on the functional characteristics of food container coatings, the following chemicals require special attention:
1. Perfluorinated Compounds (PFAS)
Many non-stick coatings contain PFAS (perfluoroalkyl and polyfluoroalkyl substances). These substances have excellent non-stick properties but also pose environmental and health risks:
- Perfluorooctanoic acid (PFOA) and its salts
- Perfluorooctane sulfonic acid (PFOS) and its salts
- Other long-chain PFAS
From August 12, 2025, restrictions on PFAS in food contact packaging came into effect:
- Any single PFAS: ≤25 1. PFAS Analysis (ppb)
- Total PFAS: ≤250 ppb (sum of target PFAS analyses)
- Total Fluorine Content: ≤50 ppm
2. Heavy Metals
Heavy metals in coatings mainly originate from pigments and desiccants:
- Lead (Pb): Commonly found in yellow and red pigments
- Cadmium (Cd): Commonly found in red and yellow pigments
- Mercury (Hg): Found in some corrosion inhibitors
- Hexavalent Chromium (CrVI): May be found in anti-rust coatings
3. Residual Organic Solvents
Organic solvents used in the coating production process may remain in the final product:
- Benzene, Toluene, Xylene
- Methanol, Ethanol, Isopropanol
- Ethyl Acetate, Butanone, etc.
These solvents may be released during use, and their residual levels need to be controlled.
4. Formaldehyde and Formaldehyde-Releasing Agents
Some coating systems (such as amino resin coatings) may contain formaldehyde or formaldehyde-releasing substances, requiring special attention to the formaldehyde restriction requirements that came into effect on August 6, 2026.
5. Photoinitiators
Common photoinitiators used in UV-cured coatings may include:
- Benzyl ethers
- Acetophenones
- Thioxanthones
These substances may have sensitizing or endocrine-disrupting effects.
3.3 Comprehensive Detection Strategy for Coating and Substrate
Given that the eco-friendly take-out containers consist of a substrate (PP) and a coating, a comprehensive detection strategy is required:
Material Separation Detection
- Separate the coating from the substrate (if possible) and test them separately.
- For coatings that cannot be separated, the coating and substrate need to be tested as a whole.
- Use appropriate analytical methods (such as solvent extraction, thermal desorption, etc.) to extract chemical substances from the coating.
Layered Detection Methods
- Use X-ray fluorescence spectroscopy (XRF) for surface analysis to detect heavy metals in the coating.
- Use gas chromatography-mass spectrometry (GC-MS) to detect organic compounds in the coating.
- Use liquid chromatography-mass spectrometry (LC-MS) to detect PFAS. Isopolar Compounds
Migration Testing
In addition to testing the chemical content in the coating, migration testing is also required to assess the migration of these substances into food:
- Simulating different types of food (aqueous, acidic, alcoholic, oily)
- Simulating different usage conditions (room temperature, heating, microwave, etc.)
- Testing whether the migration amount meets the requirements of food contact material regulations
Overall Assessment
- Assessing the interaction between the substrate and the coating
- Considering the integrity of the coating during use
- Assessing the impact of coating aging on chemical release
IV. Testing
Choosing a suitable testing organization is crucial to ensuring REACH testing compliance. According to EU regulations and industry best practices, testing organizations should possess the following qualifications and capabilities:
Basic Qualification Requirements
- CMA (China Metrology Accreditation): Indicates that the testing organization has passed China Metrology Accreditation and is qualified to issue notarized data to the public.
- CNAS (China National Accreditation Service for Conformity Assessment) Accreditation: Indicates that the testing organization's management system and technical capabilities comply with ISO/IEC 17025 standards.
- International Mutual Recognition Qualification: Such as through ILAC-MRA (International Laboratory Accreditation Cooperation Multilateral Recognition Agreement), ensuring that test reports are mutually recognized internationally.
REACH Testing Capabilities
- Capability to test for 251 SVHC substances
- Familiarity with the testing methods for restricted substances in REACH Annex XVII
- Capability to test for food contact materials (compliant with EU 10/2011 requirements)
- Possession of professional chemical analysis equipment (such as GC-MS, LC-MS/MS, ICP-MS, XRF, etc.)
Industry Experience and Case Studies
- Experience in testing plastic products, especially food contact materials.
- Familiar with EU regulatory updates and able to provide the latest compliance guidance.
- Able to provide one-stop service from sample pretreatment to report issuance.
Service Capabilities Required
- Provide test reports in both Chinese and English.
- Provide compliance consulting services to assist companies in interpreting test results.
- Able to develop customized testing solutions based on company needs.
- Provide follow-up regulatory update notification services.
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