International Compliance: REACH, RoHS, and Protective Film

For manufacturers and procurement managers sourcing surface protection films for use in the European Union—or supplying finished goods into EU markets—regulatory compliance is not a formality. REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) and RoHS (Restriction of Hazardous Substances) directly shape which protective films can be specified, how supplier documentation must be structured, and what risks arise from non-compliant materials in your production chain. This guide breaks down what each regulation requires, how they interact for protective film applications, and how to evaluate a film supplier's compliance posture before committing to an order.

Why Compliance Matters for Protective Film Procurement

Protective films are intermediate articles—they travel with workpieces through fabrication, transport, and installation before being removed. But "temporary" does not mean "unregulated." Under REACH, any article imported or sold in the EU must satisfy substance disclosure and restriction obligations, regardless of whether the item is a finished product or a process consumable. Under RoHS, if your end product is electrical or electronic equipment (EEE), every homogeneous material within it—including any adhesive residue that could remain on components—must fall within concentration limits for ten restricted substances.

The business stakes are significant. Non-compliance can result in product recalls, fines, and loss of EU market access. For procurement teams running Just-in-Time production, a compliance hold at customs or a failed audit is a disruption with direct cost consequences. Choosing a film supplier that maintains up-to-date compliance documentation reduces that risk at the source.

REACH: Scope, Structure, and What It Means for Films

Registration and Downstream Obligations

REACH (EC No. 1907/2006) entered into force on June 1, 2007 and covers the manufacture, import, supply, and use of chemical substances in the EU. Registration is required for any substance brought into the EU in quantities exceeding 1 metric tonne per company per year. For protective film manufacturers, the polymers, adhesive systems, plasticizers, and stabilizers that make up their films must be either registered by the upstream chemical supplier or confirmed exempt.

As a downstream user or importer, your direct obligations under REACH focus on three areas:

• SVHC disclosure: If a film article contains any Substance of Very High Concern (SVHC) from the ECHA Candidate List at a concentration above 0.1% by weight, your supplier must inform you and you must pass that information down your supply chain.
• SCIP notification: Since January 2021, companies supplying articles containing SVHC above 0.1% must submit information to the ECHA SCIP Database under the EU Waste Framework Directive (WFD 2018/851).
• Annex XVII restrictions: Certain substances are outright restricted in articles. For PE protective films specifically, REACH Annex XVII, Entry 51, paragraph 4a applies to polyethylene films used on precision industrial panels.

The SVHC Candidate List: A Moving Target

The SVHC Candidate List is updated twice per year by ECHA. As of January 2024, ECHA added five new substances, bringing the total to 240 SVHCs. Of those additions, two substances—OAPP (CAS 700-960-7) and a UV ink/coating compound (CAS 3147-75-9)—are particularly relevant to adhesive and coating applications, meaning they could appear in the adhesive layer or UV-stabilized topcoat of protective films.

The practical implication: a film that was fully compliant 18 months ago may now require an updated SVHC declaration. Procurement teams should request current (dated within 12 months) REACH Declarations of Conformity (DoC) from suppliers, not rely on documentation issued during initial qualification.

RoHS: Scope, Substances, and Film Applications

RoHS Applies Primarily to EEE—But the Link to Films Is Real

The EU RoHS Directive (2011/65/EU, recast) restricts ten specific hazardous substances in electrical and electronic equipment. REACH applies broadly to all products; RoHS is narrower, targeting EEE only. However, if your facility produces EEE components—circuit boards, enclosures, power supplies, control panels, sensors, lighting—and you use protective films during fabrication or on the finished units, RoHS compliance of the film's constituent materials becomes directly relevant.

The ten restricted substances and their maximum concentration limits in homogeneous materials are:

Sources: ComplianceGate RoHS substance list; Elchemy REACH/RoHS materials guide.

Phthalates: The Critical Issue for PVC Protective Films

The four phthalate plasticizers (DEHP, BBP, DBP, DIBP) were added to the RoHS restricted list in 2019. All four must remain below 1,000 ppm (0.1%) concentration in homogeneous materials. This is significant because PVC-based protective films are plasticized—without a plasticizer, PVC would be rigid and unusable as a flexible film. Historically, phthalates like DEHP were the plasticizers of choice. Modern RoHS-compliant PVC films use alternative plasticizers (e.g., DINP, DPHP, or citrate esters) that fall outside the restricted substances list.

For procurement teams, this means PVC protective films sourced before 2019 or from suppliers who have not updated their formulations may not satisfy current RoHS requirements. Always request a test report from an accredited third-party laboratory confirming phthalate content below 0.1% by weight.

REACH vs. RoHS: Key Differences at a Glance

Source: Assent REACH vs RoHS compliance guide.

Film Substrate Types and Compliance Risk Profile

Polyethylene (PE) Films

PE films—including LDPE and LLDPE variants—are the lowest-risk substrate from a REACH/RoHS perspective. Polyethylene itself is chemically inert, requires no plasticizer, and does not require lead-based heat stabilizers. The primary compliance watch points are the adhesive system and any UV stabilizers or color masterbatches added to the film. A well-formulated PE protective film from a reputable supplier will typically generate a clean SVHC declaration with no detections above the 0.1% threshold.

Polypropylene (PP) Films

Similar compliance profile to PE. PP does not require plasticization. The compliance risk centers on antioxidant packages, slip additives, and adhesive chemistry. Clarification on adhesive composition—whether water-based acrylic, hot-melt, or UV-cured—is worth including in supplier qualification requests, as some older adhesive formulations use solvents or compounds that appear on the SVHC Candidate List.

PVC Films

PVC protective films carry the highest inherent REACH/RoHS risk due to the need for plasticizers, heat stabilizers, and UV stabilizers. Legacy PVC film formulations may contain phthalate plasticizers restricted under RoHS, organotin heat stabilizers that are SVHC candidates, or cadmium-based pigments. Modern compliant PVC films replace these with DINP/DPHP plasticizers, calcium-zinc or organic heat stabilizers, and inorganic pigments. Request third-party SGS or Intertek test reports confirming compliance with the current substance lists.

TPU Films

Thermoplastic polyurethane films—used for high-performance surface protection, particularly in metal fabrication and paint protection applications—generally exhibit a favorable compliance profile. Independent testing of TPU-based surface protection films by Intertek has confirmed no SVHC detected above the 0.1% threshold under REACH Article 33(1). The main watch point is isocyanate-based raw materials used in TPU synthesis; these must be confirmed as properly reacted and not present as free isocyanates in the finished film.

Documentation Requirements for Supplier Qualification

When qualifying a protective film supplier for EU-market production, your compliance documentation package should include:

Minimum Required Documents

• REACH Declaration of Conformity (DoC): Must reference the current SVHC Candidate List (minimum 240 substances as of early 2024), include a statement on Annex XVII restrictions, and be dated within the past 12 months.
• Safety Data Sheet (SDS): Required for chemical substances and preparations. Even when not strictly required for articles, an SDS communicates composition and hazard information relevant to safe handling on your production floor.
• RoHS Declaration / Test Report: For films used in EEE applications, a third-party lab test report from an accredited body (SGS, Intertek, TÜV, Bureau Veritas) confirming restricted substance concentrations below threshold limits.
• SCIP Notification Confirmation: If the film contains any SVHC above 0.1%, the supplier must confirm they have submitted SCIP notifications to ECHA.

Enhanced Diligence for High-Risk Applications

• Full material composition disclosure (resin, adhesive, additive packages)
• PFAS declaration (per- and polyfluoroalkyl substances have seen increased REACH scrutiny)
• Conflict minerals declaration (CMRT) for films entering supply chains with broader ESG reporting obligations
• California Prop 65 compliance statement for products also shipped to North America

Practical Compliance Workflow for Procurement Teams

Step 1: Classify Your Film Application

Determine whether your end product will be sold as EEE in the EU. If yes, both REACH and RoHS documentation are required. If your end product is not EEE—aluminum panels, architectural profiles, industrial machinery—REACH compliance remains mandatory but RoHS requirements do not formally apply to the finished article.

Step 2: Request Current Documentation at Order

Do not rely on compliance documents obtained during initial supplier qualification if more than 12 months have elapsed. The SVHC Candidate List is updated twice per year; a document from two years ago may miss recently added substances. Make current compliance documentation a condition of each purchase order for regulated markets.

Step 3: Verify Third-Party Test Data

Supplier self-declarations carry limited weight in formal audits. Request test reports from recognized third-party laboratories. RoHS compliance requires manufacturers to draw up technical documentation, an EU Declaration of Conformity, and attach the CE mark to their EEE products—supporting third-party test data is the foundation of that technical file.

Step 4: Monitor Regulatory Updates

ECHA's January 2024 update added five substances to the SVHC list, affecting primarily adhesives, coatings, and UV inks—all relevant to protective film formulations. Assign a compliance owner within your procurement or quality function to track ECHA updates and alert suppliers when new substances affect your film specifications.

Internal Links: Related Film Selection Resources

Understanding compliance requirements is one part of the protective film selection process. Explore the full Alufilm product range to review substrate options, adhesive types, and thickness specifications for aluminum surface protection. Each product in the Alufilm portfolio is manufactured with current EU compliance requirements in mind, and compliance documentation is available on request.

Conclusion

REACH and RoHS compliance for protective films is a supply chain discipline, not a one-time checkbox. The SVHC Candidate List grows with each ECHA update cycle; RoHS has expanded its restricted substance list over successive revisions; and documentation that satisfied an audit two years ago may fall short today. For manufacturing teams sourcing protective films for EU production or EEE applications, the practical priorities are clear: qualify suppliers on documented compliance, not self-certification alone; request dated declarations with every order; and track ECHA updates as part of routine procurement due diligence.

Alufilm supplies aluminum protective films manufactured to current EU regulatory standards. Our technical team can provide REACH Declarations of Conformity and third-party test documentation to support your compliance requirements. Contact Alufilm to discuss your specification and obtain compliance documentation for your procurement file.