Are printed paper products subject to REACH and RoHS?

I now work for a printer of folder inserts, self adhesive labels, booklets, and the like.

Just got a request from a cutomer for a REACH and RoHS analysis on the parts we supply.

First question: How applicable is this?

I am not an expert by any means, but I do know that RoHS restricts the use of the following:

1. Lead (Pb)
2. Mercury (Hg)
3. Cadmium (Cd)
4. Hexavalent chromium (Cr6+)
5. Polybrominated biphenyls (PBB)
6. Polybrominated diphenyl ether (PBDE)

So, if you don't deal with any of those, you are off to a good start. Sorry, that is the end of my knowledge on the subject. (ok, I'm feeling pretty stupid, actually)

ScottK said:

I now work for a printer of folder inserts, self adhesive labels, booklets, and the like.

Just got a request from a cutomer for a REACH and RoHS analysis on the parts we supply.

First question: How applicable is this?

Click to expand...

RoHS is only applicable for all EEE (Electrical and Electronic Equipment) for those categories as defined within the WEE directive.
There is quite a discussion going on, what is whitin and outside of the scope for RoHS.
Nevertheless, if your customer wants you to declare yourself conform with the RoHS directive, than indeed as mentioned your products should not contain the 4 heavy metals (Lead, Mercury, Cadmium and Chromium (6+)) and 2 flame retardants PBD and PBDE on a homogeneous material level.

For RoHS, please check what kind of requirements are set by your customer.

For REACH, YES your products would be regarded as "Articles" and therefore you have the "Information" Obligation that is outlinged in Article 33 of this legislation.
In other words, if your products contain a substance for the REACH Candidate List in a concentration of 0,1% vs the total weight of the product you will have to inform your customer about this, and also describe how he can safe use your products.

You can find the substances that are currently included in the list here:
http://echa.europa.eu/chem_data/authorisation_process/candidate_list_en.asp

There are lots of materials to be found on REACH in this forum, so if you need more information, I guess you could spend some time on reading other topics on this subject.

I hope this Post already gives you some idea.