Article originally published in the Food Packaging Bulletin, January 2010

As with virtually all goods manufactured in, or imported into, the European Economic AreaI, food packaging is subject to the stringent requirements of Regulation (EC) No. 1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals (the so-called “REACH Regulation”)II. Indeed, while substances “used in food” are excluded from most of the REACH requirements, this is not the case for substances used in the manufacture of food packaging or from which food packaging is made.

The REACH Regulation applies to substances on their own and in mixtures, as well as to substances in so-called “articles”. Articles are objects, such as packaging, that during production are given a special shape, surface or design that determines their function to a greater degree than their chemical composition.

REACH is characterized by the following features: First, for virtually all substances, REACH imposes the principle of “no data, no market” and requires producers to learn about and disclose the substances that are contained in their products and their properties.

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Photo of Cándido García Molyneux Cándido García Molyneux

Cándido García Molyneux provides clients with regulatory, policy and strategic advice on EU environmental and product safety legislation. He helps clients influence EU legislation and guidance and comply with requirements in an efficient manner, representing them before the EU Courts and institutions.

Cándido…

Cándido García Molyneux provides clients with regulatory, policy and strategic advice on EU environmental and product safety legislation. He helps clients influence EU legislation and guidance and comply with requirements in an efficient manner, representing them before the EU Courts and institutions.

Cándido co-chairs the firm’s Environmental Practice Group.

Cándido has a deep knowledge of EU requirements on chemicals, circular economy and waste management, climate change, energy efficiency, renewable energies as well as their interrelationship with specific product categories and industries, such as electronics, cosmetics, healthcare products, and more general consumer products.

In addition, Cándido has particular expertise on EU institutional and trade law, and the import of food products into the EU. Cándido also regularly advises clients on Spanish food and drug law.

Cándido is described by Chambers Europe as being “creative and frighteningly smart.” His clients note that “he has a very measured, considered, deliberative manner,” and that “he has superb analytical and writing skills.”