01 CHEMICAL-COMPLIANCE EVIDENCE ROUTING
REACH SVHC vs RoHS for film and foil: route the evidence before requesting a declaration
Start with three routes, not one generic compliance certificate. An exact film or foil item may need REACH Candidate List and Article 33 communication evidence, may contribute material evidence to a downstream electrical or electronic equipment technical file under RoHS, or may need a different regulatory owner. Fix the supplied item, complete structure, intended use, market, legal object and dated source before asking a supplier for documents.
02 DECISION FRAME
Choose Article 33, downstream EEE evidence or another owner before comparing documents
REACH and RoHS answer different questions. ECHA's article-information pages connect Candidate List inclusion with supply-chain obligations for qualifying articles, while Directive 2011/65/EU places RoHS restrictions within electrical and electronic equipment scope. General packaging film is not automatically inside that RoHS scope. A film or foil declaration, analytical report or supplier questionnaire can be one controlled input to a downstream EEE technical file; it is not by itself the finished EEE manufacturer's EU declaration of conformity or a legal conclusion for every use.
- A buyer who has received a broad request for REACH, SVHC or RoHS documents but has not fixed the exact item, construction, use or market
- A converter comparing supplier declarations or test reports that use different Candidate List dates, substance scopes, thresholds, lots or factories
- An industrial-film or foil project that must separate downstream EEE technical-document inputs from packaging, food-contact or other regulatory evidence
- There is no generic REACH certificate and this guide supplies no all-substance, all-grade or all-use REACH conclusion
- Packaging film or foil is not automatically within RoHS scope because a customer requests a RoHS questionnaire
- A limited analyte panel, old Candidate List snapshot, one lot, one layer, one grade or one factory covers every substance, construction, source or future order
- No LayerSource grade, supply route, factory, declaration, laboratory, test report, certification or compliance capability is established
03 COMPARISON MAP
Keep the three routing decisions and their evidence boundaries separate
Review one identified item and use. This matrix provides no legal opinion, substance count, universal analyte panel, customer limit, exemption decision or pass/fail rule.
Swipe or scroll horizontally to review every evidence column.
| Evidence route | Question it can address | Context to retain | Conclusion it cannot create alone |
|---|---|---|---|
| Exact item, role, use and market | What is supplied, how is it classified for the review, where will it be used and which responsible operator owns the decision? | Grade and lot; complete layers, coatings, inks, adhesives, treatments and metal; article, material, component or EEE role; intended use, destination and responsible reviewer | A legal classification, market access, product approval, supplier capability or result for another construction or use |
| Route 1 — REACH Candidate List / Article 33 | Does the responsible owner require current Candidate List article-communication evidence for the exact supplied object? | Current ECHA list snapshot and date; REACH edition; article boundary; declaring entity and factory; substance identity and concentration basis; communication content and recipient | A generic REACH certificate, absence of every restricted substance, registration conclusion, authorization, restriction compliance or result beyond the reviewed object |
| Route 2 — downstream EEE RoHS evidence | Is the film or foil being assessed as a material or component input to a defined downstream EEE technical file? | Current Directive edition; EEE and homogeneous-material boundaries; downstream product and economic operator; substance scope; declaration, report or technical-document role; exemptions and dates | That general packaging film is in RoHS scope, that the material record is a finished-EEE EU declaration of conformity, or that every downstream product complies |
| Route 3 — another regulatory owner | Is the buyer actually asking about food contact, packaging heavy metals, POPs, PFAS, SCIP, California Proposition 65 or another separate regime? | Exact question, market, product role, responsible legal or regulatory owner, controlling text and required record kept outside this route | An all-chemical-compliance answer, cross-regime equivalence or a conclusion from a REACH or RoHS document |
| List, law and document snapshot | Which official list or legal consolidation and which supplier-document revision controlled the review? | Official source URL, checked date, consolidation or edition, declaration revision, issue date, validity or review date and superseded records | That an undated declaration, blocked page, search snippet or old list remains current |
| Substance, threshold and exemption scope | Which named substances or analytes, legal or customer threshold basis and exemptions are actually represented? | Substance names and identifiers, list scope, article or homogeneous-material boundary, threshold source, exemption reference, applicability owner, expiry and unresolved gaps | Coverage of unlisted analytes, every SVHC, another threshold basis, future list additions or an exemption outside its exact application |
| Declaration, test and lot evidence | What does each controlled record say, who issued it and what production population does it represent? | Entity, factory, grade, construction, lot and sample; declaration or report role; method, laboratory, sampling and analyte panel where testing is used; original result and limitations | That a supplier declaration and laboratory report are interchangeable, or that one sample proves every layer, lot, grade, factory or future order |
| Review, disposition and change control | Who accepts the bounded evidence and which changes require a new declaration, report or legal review? | Buyer and regulatory approvers, open gaps, deviations, disposition, review date and triggers for substance, formulation, layer, process, supplier, factory, law, list or intended-use change | Permanent approval, certification, warranty, legal advice or a LayerSource compliance decision |
04 SELECTION SEQUENCE
Move from a broad comparison to an approvable decision.
Freeze the supplied object and downstream role
Name the exact grade, complete layer and surface structure, factory and lot, then record whether the review concerns an article, a material or component input, finished EEE or another object. Leave the legal classification with the qualified owner.
Select one evidence owner at a time
Route the question to REACH Article 33, downstream EEE RoHS technical documentation or a separately named regulatory regime. Do not let one declaration answer multiple laws by implication.
Attach the snapshot, scope and change gate
Retain the current official source, declaration revision, analyte and threshold basis, lot and factory coverage, limitations, reviewer and change triggers before a buyer-owned disposition is recorded.
05 RFQ INPUTS
REACH SVHC and RoHS film/foil evidence RFQ checklist
Use exactly these twenty-one fields. Unknown legal or technical fields remain open for the buyer, supplier and qualified regulatory reviewer; this page supplies no compliance decision, default test panel or declaration wording.
Open the RFQ brief builder ↗- 01
Buyer project, exact regulatory question, intended decision and responsible acceptance owner
- 02
Exact film or foil item, supplier grade or order code and controlled document revision
- 03
Complete monofilm, coextrusion, coating, print, adhesive, laminate, treatment, deposited-metal and foil layer/surface structure
- 04
Declaring supplier entity, manufacturing factory or site and relationship to the supplied item
- 05
Batch, lot, roll, sample, report and chain-of-custody identifiers
- 06
Intended application, downstream product, destination market and economic-operator role
- 07
Article, material, homogeneous material, component, EEE or other legal object recorded for qualified review
- 08
Selected REACH, RoHS or separately named regulation with official URL, current consolidation or edition and contractual precedence
- 09
Dated ECHA Candidate List snapshot where SVHC evidence is requested, without a hard-coded substance count
- 10
Declaration owner, signatory role, issue date, revision, covered item and next review or validity date
- 11
Named substances, substance identifiers and exact Candidate List, Annex or customer analyte scope
- 12
Legal or customer threshold source and the applicable article, homogeneous-material or other calculation boundary
- 13
Method, edition, laboratory, accreditation scope and original report reference where testing is used
- 14
Sampling plan, tested layer or homogeneous material, lot coverage, detection/reporting basis and limitations
- 15
Supplier declaration, analytical report, questionnaire and downstream technical-file roles kept separate
- 16
RoHS exemption reference, exact application, responsible applicability decision, expiry and renewal status where relevant
- 17
Article 33 communication content, recipient, issue route and evidence record where the qualified owner determines it applies
- 18
Food-contact, packaging-heavy-metal, POPs, PFAS, SCIP, Proposition 65 and other excluded questions routed to named owners
- 19
Missing substances, layers, factories, lots, methods, dates, signatures, evidence and unresolved legal questions
- 20
Buyer and qualified regulatory-review approval, deviation, concession, retest or additional-document disposition
- 21
Substance, formulation, layer, coating, supplier, factory, process, list, law, exemption, use or market changes that trigger review
06 EVIDENCE BOUNDARY
Official sources route evidence; they do not create a universal film or foil compliance result
The ECHA Candidate List is the authentic live list published under REACH Article 59(10); it can change, so this editorial review records a 2 August 2026 snapshot and does not hard-code a substance count. ECHA's Candidate List substances-in-articles and supply-chain communication pages explain that inclusion can trigger obligations for qualifying articles and that Article 33 communication is tied to the identified substance, article and concentration context. Classification and applicability for the supplied item remain decisions for the responsible qualified owner. Regulation (EC) No 1907/2006 was checked in its EUR-Lex consolidation of 11 May 2026. Directive 2011/65/EU was checked in its EUR-Lex consolidation of 1 July 2026; its subject and scope concern electrical and electronic equipment, and the finished EEE manufacturer owns its conformity assessment and EU declaration. Commission Implementing Decision (EU) 2020/659 publishes the reference to EN IEC 63000:2018 for technical documentation used to assess materials, components and EEE with respect to restricted substances. This page cites that public status only and reproduces no paid standard procedure. A supplier declaration or report remains a bounded input, not a finished-EEE EU declaration of conformity. An access error or blocked page is not evidence. This page provides no legal advice, legal classification, universal analyte panel, fixed customer threshold, exemption decision, declaration template, compliance result or certification. It establishes no LayerSource film, foil, grade, inventory, supplier relationship, factory, declaration, laboratory, testing, technical-file, certification, legal-review, compliance or supply capability or result. Packaging heavy metals, POPs, PFAS, SCIP, California Proposition 65, food-contact and other regulatory regimes remain separate. The buyer, supplier, downstream product owner, responsible economic operator, laboratory and qualified legal or regulatory reviewer must approve the current sources, scope, evidence and bounded disposition before use.
07 BUYER QUESTIONS
Resolve the assumptions that make quotes diverge.
01Is there a generic REACH certificate for film or foil?+
This guide treats a request for a generic certificate as an unresolved evidence question. Identify the exact supplied object, applicable REACH duty, current Candidate List snapshot, declaring entity, substance scope and supporting record. A broad certificate label is not substituted for that review.
02Is packaging film automatically subject to RoHS?+
No automatic scope conclusion is made. RoHS concerns electrical and electronic equipment. If film or foil is intended for a downstream EEE construction, the responsible product owner may request bounded material or component evidence for its technical file; that evidence does not make every packaging use a RoHS use.
03Does a supplier RoHS declaration replace the finished-EEE EU declaration of conformity?+
No. A supplier material declaration can be retained as one technical-document input. The finished EEE manufacturer—or an importer or distributor treated as the manufacturer under applicable law—owns the applicable conformity assessment, technical file and EU declaration of conformity. Other economic operators retain their separate applicable duties.
04Does a limited laboratory panel prove that no Candidate List substance is present?+
No. Keep the named analytes, methods, reporting basis, tested layer or homogeneous material, sample and lot, laboratory, date and limitations visible. Do not extend a finite panel to substances, layers, grades, factories, lots or future list additions that it did not cover.
05Can an old SVHC declaration be reused for a new order?+
Only after the responsible owner reviews the current Candidate List, declaration revision, supplied item, factory, formulation, layers, lot scope, intended use and change history. This page supplies no automatic validity period or reuse decision.
06Does this guide cover food contact, SCIP, PFAS or packaging heavy metals?+
No. Food-contact evidence has its own guide. SCIP, PFAS, packaging heavy metals, POPs, California Proposition 65 and other regimes require separately identified legal texts, objects, owners and evidence routes.
07Does this guide prove LayerSource supplies compliant film or issues declarations?+
No. This editorial evidence-routing page identifies no LayerSource grade, supplier relationship, factory, declaration, test report, laboratory, certification, compliance result, regulatory service or supply capability.