Tips to help you ensure compliance with regulations around PCR plastic

Regulations are even more important with recycled content

Understanding regulations can be tedious, but it is often a key foundation stone for making sure your products are both compliant and safe. Using PCR (Post-Consumer Recycled) material can be beneficial for sustainability, provided that you avoid any potential pitfalls to ensure that it is safe, clean, and consistent. Our team are definitely not legal and compliance advisors, but we have compiled a list - by no means exhaustive - of regulations which can apply to PCR plastic products, particularly in Europe. Some of these are quite common and essential to understand, while others may be more peripheral whilst also being interesting to understand. 

 

REACH 1907/2006/EC - SVHC

This particular directive relates to restrictions and limitations on substances. Within this directive lies the SVHC (Substance of Very High Concern) candidate list. If a material contains any SVHC in excess of 0.1% weight, importers, producers and suppliers are required to report the presence of an SVHC within 45 days of a request from consumers or customers. For more information about the SVHC candidate list and the REACH directive, click here: https://echa.europa.eu/candidate-list-table 

 

RoHS 2 + 3 (Restriction of Hazardous Substances)

This is applicable for the electronics and electrics industries, so while it may not be directly relevant to Richmond's range of packaging, you may encounter it within other elements of your range, such as haircare and skincare tools or applications. It ensures that producers and suppliers do not manufacture materials that contain any of the 10 following substances, or exceed any of the values stated: 

• Cadmium (Cd): < 100 ppm
• Lead (Pb): < 1000 ppm
• Mercury (Hg): < 1000 ppm
• Hexavalent Chromium: (Cr VI) < 1000 ppm
• Polybrominated Biphenyls (PBB): < 1000 ppm
• Polybrominated Diphenyl Ethers (PBDE): < 1000 ppm
• Bis(2-Ethylhexyl) phthalate (DEHP): < 1000 ppm
• Benzyl butyl phthalate (BBP): < 1000 ppm
• Dibutyl phthalate (DBP): < 1000 ppm
• Diisobutyl phthalate (DIBP): < 1000 ppm

To find out more about the RoHS compliance, please use this link: https://www.rohsguide.com/

 

Packaging directive 94/62/EC

Originating in the EU, the Packaging Directive 94/62/EC is in place to make sure that packaging and packaging waste is of an environmentally and health friendly nature. The directive also restricts the concentration levels of heavy metals, such as lead, cadmium, mercury and hexavalent chromium, to 100ppm by weight. In addition to this, the regulation has an underlying objective of encouraging reduce, reuse, recycle. For a straightforward overview of this directive, please visit: https://deutsche-recycling.com/packaging-regulation/the-european-packaging-directive/ 

 

Producer Responsibility Obligations (Packaging Waste) Regulations 2007

In the UK, this and the amendment Packaging (Essential Requirements) Regulations 2015, implements the above directive: 94/62/EC. For England and Wales, this is soon to be replaced by the Environmental Permitting Regulations (EPR 2016), and in Scotland the Waste Management Licensing Regulations 2011. To find out more about EPR, browse here.

 

Plastic Packaging Tax Regulations UK

As of 1st April 2024, this increases to £217.85 per tonne of plastic which contains less than 30% recycled content. Read more details about the tax regulation here.

 

 

When it comes to plastic packaging regulations, this blog barely scratches the surface on the vast number of different directives out there. Therefore, it is important to mention that although we will do all we can to help you become compliant, be sure to seek out your own legal advice if you're thinking of using PCR material in your packaging. 

 

To discuss any further details regarding your plastic packaging compliance, including the use of any bespoke materials to help ensure adherence to any specific regulation of concern, please use our contact details here.