关于REACH中包装材料的规定

关于包装材料的义务
塑料包装材料在REACH法规下被视为“物品”单独进行考虑，需要履行物品相关的通报和信息传递的义务，在计算其高关注物质含量时不需要考虑所包装的物质的重量。具体内容解释见“Guidance on requirements for substances in articles”

2.2 Notification according to Article 7(2)
The obligation to notify substances in articles also applies to packaging materials, which may be produced or imported separately as packaging of imported goods. Packaging is to be assessed separately from any object it contains.


2.3 Obligations according to Article 33
The obligation to forward available information on substances of very high concern on the candidate list also applies to packaging materials. This packaging material is always a separate ‘article’. Thus, if the imported buttons or the imported jackets were packaged in plastic packaging material, the content of such substances in this packaging material would have to be assessed separately.

2.7 Packaging and containers
The packaging material does not belong to the substance/preparation or article being packaged. Producers/importers of packaging or of packaged substances, preparations or articles have to fulfil the same requirements for that packaging as for any other article.

Normally there is no intended release from packaging materials. There may be exemptions, e.g. packaging releasing corrosion inhibitors. In this case the release is intended (the function is to prevent corrosion) and constitutes an accessory function of the article (the main function is to protect the object contained inside the packaging from any damage during transport and storage). For further guidance see Chapter 3

一般来说包装材料不存在合理释放的情况，但也有例外，如能释放缓蚀剂的包装材料，这时候可能还要履行注册义务。