The 100 mg/kg heavy-metal cap is only the chemical floor for packaging under Regulation (EU) 2025/40 (PPWR). The wider chemical file — REACH SVHC communication, ECHA SCIP notification and risk-based review of printing inks and volatile compounds — increasingly appears in European battery customers' supplier questionnaires. This paper builds that supplementary file for nickel-metal hydride (NiMH) packaging.
REACH (EC) 1907/2006 applies to packaging as it does to any article. If any packaging component contains a substance of very high concern (SVHC) from the candidate list above 0.1 % weight by weight, Article 33 requires the supplier to communicate safe-use information to downstream recipients on request, and the EU importer placing that article on the market must submit the data to ECHA's SCIP (Substances of Concern In articles as such or in complex objects Products) database under the Waste Framework Directive. The candidate list updates twice yearly, so compliance is a monitoring task, not a one-time declaration. Printing inks, plasticisers, certain pigments and adhesives are the typical SVHC entry points in battery packaging.
A SCIP notification identifies the article (by name and category), the SVHC above 0.1 % with its concentration range and location, the material composition and safe-use and disposal instructions. Notifications are submitted per article or complex object through the ECHA submission portal and carry an SCIP ID referenced in customer files. The exporter's role is to supply the underlying material data — the legal notification belongs to the EU-side operator — which means material declarations from board, plastic, ink and adhesive vendors are the rate-limiting input. Best practice is a per-component declaration refreshed with each candidate-list update and a standing rule that any new ink colour or adhesive triggers re-screening.
The PPWR does not impose a universal volatile-organic-compound limit on transport packaging, but its recyclability and source-reduction requirements make VOC and ink assessment best practice, and several national and buyer-specific schemes go further: heavy-metal-free inks, low-VOC water-based adhesives, minimal ink coverage for fibre packaging (de-inking recyclability under EN 13430 design criteria), and restrictions on mineral-oil hydrocarbons in paper food-contact contexts. For battery packaging the pragmatic file includes: ink and adhesive supplier SDSs; a statement of mineral-oil and phthalate status; total VOC or solvent content where printing processes use them; and a de-inking/recyclability note for printed fibre packaging. PFAS restrictions are tightening fast — food-contact packaging faces direct PPWR PFAS prohibitions, and industrial buyers increasingly demand fluorine-free treatment even where not mandated.
Efficient exporters maintain one chemical-compliance system covering product and packaging together: the same IEC 62321 lab tests metals in both; the same REACH candidate-list monitoring drives SVHC statements for sleeves and cartons; the same supplier-declaration register feeds the battery Annex I file and the PPWR Annex VIII file. This avoids the common audit failure of a perfect battery dossier sitting next to a packaging folder containing only an undated "compliant" letter. The scorecard above illustrates the maturity gap buyers score: a documented pack screens SVHCs, stands SCIP-ready, assesses inks and demonstrates recyclability; a generic pack asserts compliance; an absent file fails the questionnaire outright.
The supplementary chemical pack should contain: per-component material declarations with resin/grade identification; SVHC statement keyed to the current candidate-list version; SCIP-ready data set (article IDs, concentrations, locations) for the importer; ink/adhesive SDSs and VOC/mineral-oil statements; heavy-metal reports to IEC 62321; PFAS-free statement where applicable; the EN 13430 recyclability/de-inking assessment; and a change-control rule tying supplier or colour changes to re-assessment. Dates, versions and signatories on every document turn a pile of PDFs into an auditable system.
Weijiang Power maintains a unified chemical file across NiMH cells and packaging: current-version SVHC statements, SCIP-ready data sets, ink and adhesive declarations, IEC 62321 metal reports and PFAS-free options, all version-controlled and refreshed with each candidate-list update. Forward your customer's chemical questionnaire and we return matched, dated declarations for both product and packaging in one response.
