ECHA ran an informal consultation on a draft list of roughly 700 candidate substances of concern in packaging, prepared under the Packaging and Packaging Waste Regulation, and it closed on 24 August 2026. This sits outside REACH proper, but it’s run by ECHA and draws heavily on REACH-derived hazard data, which makes it worth tracking alongside our usual REACH and CLP coverage rather than treating it as unrelated.
What the list actually is
The roughly 700 substances were screened down from an initial list of around 6,000, assessed against chemical safety and recyclability criteria together, rather than chemical hazard alone. That combination is worth noting: a substance can end up flagged here partly because of how it affects recyclability, not purely because of a REACH-style hazard classification.
Why this is worth tracking despite having no legal effect yet
The draft list itself doesn’t create any obligation today. It’s an informal consultation on a candidate list, not a restriction or an adopted regulation. But the Commission and ECHA are required to publish a report on substances of concern in packaging by 31 December 2026, and that report is the real signal to watch for. A list of 700 candidate substances narrowing down through a formal process, with a firm reporting deadline already fixed, tends to lead somewhere.
Who this actually affects
This is a wider audience than most REACH restrictions reach. It’s not limited to packaging manufacturers. Any business shipping products in printed, coated or multi-layer packaging has some exposure here, whether or not packaging has ever been part of their regulatory compliance thinking before. If your product compliance work has always stopped at the product itself and never extended to what it ships in, this is worth changing.
What to do now
- No action is required this week. There’s no legal obligation attached to the draft list itself.
- Flag internally that a substance list is forming specifically around packaging, distinct from your existing product-level REACH and CLP compliance work.
- If your products ship in printed, coated or multi-layer packaging, note the 31 December 2026 report as the date to check back on, since that’s when the process moves from informal consultation to something more concrete.
- Start thinking about packaging as its own compliance category if you haven’t already, rather than an afterthought to the product itself.
How we can help
We help clients extend their compliance thinking beyond the product itself to cover packaging, and keep watch on developments like this one that sit adjacent to REACH rather than inside it. Get in touch if you’d like us to review your packaging exposure ahead of December’s report.
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