The paperwork behind your labels matters more than it used to. Here is what to ask for, and what each document actually claims.
If you sell into the European Union, a date is coming up fast. The EU Packaging and Packaging Waste Regulation applies from August 12, 2026, replacing a packaging directive that had been in place since 1994. Unlike a directive, a regulation applies directly in all 27 member states with no national transposition, so the same rules land everywhere at once. (European Commission)
That deadline is one reason compliance questions are showing up earlier in the buying conversation than they used to. Quality and regulatory teams now want documentation before an order is placed, not after an audit finds a gap.
Here are the six documents we keep current at SixB Labels, what each one covers, and how to read them.
1. TSCA Section 6(h) PBT declaration
The Frank R. Lautenberg Chemical Safety for the 21st Century Act required the EPA to take expedited action on five persistent, bioaccumulative, and toxic chemicals: DecaBDE, PIP (3:1), 2,4,6-TTBP, HCBD, and PCTP. (U.S. EPA)
A PBT declaration from your printer should state whether those five substances are intentionally added during manufacturing. Ours does.
2. PFAS, PFOS, and PFOA declaration
PFAS questions now reach nearly every material category, and pressure-sensitive labels are no exception. This declaration addresses whether per- and polyfluorinated substances are used as ingredients in label manufacturing.
3. REACH, RoHS, and California Proposition 65 compliance
This is usually the workhorse document. A good one covers several frameworks at once:
- REACH (EU 1907/2006), including the Candidate List of substances of very great concern, which reached 253 entries when ECHA added two substances on February 4, 2026 (ECHA Candidate List)
- RoHS 3 (EU 2015/863) concentration maximums for cadmium, mercury, lead, hexavalent chromium, and the restricted phthalates
- California Proposition 65 chemicals requiring a warning
- Allergen and TSE/BSE freedom per Annex II of Regulation (EU) 1169/2011
- The Model Toxins in Packaging Legislation, formerly known as CONEG
- Conflict minerals
- FDA 21 CFR 175.105 and 177.1520 for the films and adhesives used in production, which matters for food-contact applications
Worth noting: the SVHC list is updated roughly twice a year. A REACH letter dated eighteen months ago is not the same as a current one.
4. EU POP certification
The Persistent Organic Pollutants regulation (EU) 2019/1021 carries its own PFOA and PFOS restrictions under Annex I, Part A. It sits alongside REACH rather than inside it, which is why it needs its own document.
5. EU PPWR certification
This is the newest addition, and it covers Regulation (EU) 2025/40 on packaging and packaging waste. (EUR-Lex)
One distinction to keep straight: our PPWR certification addresses the packaging materials supplied with SixB products. Your own product packaging carries its own obligations, and your finished-goods packaging supplier will need to speak to those.
6. Conflict Minerals Reporting Template (CMRT)
The CMRT is the industry-standard survey for 3TG minerals: tin, tantalum, tungsten, and gold. It is a free, standardized Excel template published by the Responsible Minerals Initiative, aligned to the OECD Due Diligence Guidance, and used to support both Dodd-Frank Section 1502 and the EU Conflict Minerals Regulation. (Responsible Minerals Initiative)
Two things to check on any CMRT you receive.
The version. RMI releases a new template most Springs, and reviewers increasingly reject old ones. Version 6.6 was released April 17, 2026, replacing 6.5, with updated smelter reference lists and new product-number fields. A declaration completed on an outdated template can look complete and still fail a customer's current requirements. Ours is 6.6, effective May 7, 2026.
The scope. The CMRT can be completed at company, division, or product level. Company-level scope is the broadest, covering the full product range rather than a single line. Ours is completed at company level, and it declares that none of the four minerals are intentionally added or used in our products or in our production process. It also confirms a responsible minerals sourcing policy, supplier surveys conducted in conformance with IPC-1755, and corrective action management.
If you already have our REACH letter, you have seen a one-line statement on conflict materials. The CMRT is the formal, comparable version of that same claim.
Certification or declaration? The difference matters
Here is the part that often gets glossed over, and it is worth understanding before you file a document away as settled.
A certification states positive compliance and should tell you what it rests on. Ours cite supplier material declarations, material composition review, internal assessments, quality management procedures, and independent laboratory testing where applicable.
A declaration states that a substance is not intentionally added as an ingredient and is not expected in the finished product. It usually stops short of saying the product is "free of" that substance, because the manufacturer has not tested for it.
A standardized template like the CMRT is a third thing altogether. Because every supplier answers identical questions in an identical format, you can lay responses side by side and compare them, which no prose letter allows.
That declaration language is not evasion. It is the honest position for any converter who buys substrates, adhesives, and inks from upstream suppliers rather than formulating them. A printer who claims laboratory-verified freedom from every regulated substance on every job is either testing far more than the industry standard or overstating the case. Ask which.
What to ask your label supplier
- Are your compliance documents dated within the past twelve months?
- Does your REACH letter reference the current SVHC Candidate List count?
- Is the document a certification or a non-intentional-addition declaration?
- What is the stated basis: supplier declarations, internal review, or independent testing?
- Is your CMRT completed on version 6.6, and at what scope?
- For EU shipments, do you have PPWR documentation in place ahead of August 12?
If your current supplier cannot answer those quickly, that is useful information on its own.
Simplifying the paperwork, too
We have been printing labels in Dallas since 1979, and we have watched compliance move from a back-office formality to a front-of-process requirement. Keeping this documentation current and easy to hand over is part of what simplifying labeling means to us.
Signed copies of all six documents are available on request. If you are working through a compliance review, or you want to know what applies to your product category, we are glad to talk it through.
Request a quote or request samples and let us know what documentation your team needs.
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