If you sell candles or fragrance products into the European Union, the glass jars you import are packaging, not just decoration. That means they fall under multiple EU regulations - REACH, the Packaging and Packaging Waste Regulation (PPWR), and increasingly, member-state-level legislation on cosmetic packaging.
Two of those regulations had material updates in 2024 that affect printed glass. If your supplier hasn't proactively told you about them, this is the catch-up.
What REACH actually regulates
REACH - Registration, Evaluation, Authorisation and Restriction of Chemicals - is the EU's master framework for substance safety. The relevant teeth for printed glass live in Annex XVII, the list of restricted substances.
For decorated glass packaging, the substances that matter are almost all in pigments and ink binders. Specifically:
- Lead and lead compounds - Pb<0.01% in inks intended for any consumer-contact surface
- Cadmium and cadmium compounds - Cd<0.01% in inks; tightened further in 2024 for jewellery-adjacent applications, which has been interpreted (correctly) to include premium glass packaging
- Chromium VI - <0.1 mg/kg in any decorative coating; this is the tightest restriction in the entire annex
- Phthalates (DEHP, BBP, DBP, DIBP) - relevant when the ink binder is a plasticised resin; many older decoration setups used these as flow agents
- Per- and polyfluoroalkyl substances (PFAS) - added to the restricted list in 2024, relevant for certain anti-stick coatings used on glass kiln lines
The thresholds aren't new in principle - most of them existed in some form before 2024. What changed is how strictly importers are being asked to document compliance, and the fact that several pigment ranges that used to be "compliant enough" are now off the table.
What changed in 2024 specifically
The cadmium-yellow problem
Cadmium sulfide and cadmium selenide pigments produce some of the most saturated yellows, oranges, and reds available to ceramic and glass decoration. They're also exactly what the cadmium restriction targets. In June 2024, ECHA (the European Chemicals Agency) closed a previous interpretation loophole that had allowed cadmium-based pigments in ceramic glaze "for technical reasons." That door is now closed for new product lines.
Practical impact: if your candle jar uses a saturated yellow or warm-orange screen print, ask your supplier specifically whether the pigment is cadmium-based. If yes, you have a problem for EU imports from 2025 onwards. The replacement is bismuth vanadate yellow - slightly less saturated, slightly more expensive, but compliant.
PFAS in kiln coatings
Many traditional Indian and Chinese glass decoration kilns use anti-stick coatings on the conveyor systems and decorating mandrels. Some of those coatings contain PFAS - the "forever chemicals" that finally got their REACH restriction tightened in early 2024.
The exposure to the finished product is debated (PFAS in the kiln coating doesn't migrate to the glass in any measurable way under standard operating conditions), but importer documentation increasingly asks for PFAS-free declarations across the whole production chain. Most reputable manufacturers, including us, have switched to non-PFAS silicone or ceramic-based alternatives over the past two years.
The supplier declaration cascade
The bigger structural change in 2024 is that EU importers are now expected to produce, on demand, the full substance declaration cascade: ink-maker → decoration shop → glass manufacturer → packaging-as-supplied. If any link in that chain can't produce its declaration, the import-level declaration is incomplete. Customs are starting to ask.
For a candle brand, this means your supplier needs to be able to send you, for every decorated SKU:
- A REACH declaration from the ink manufacturer (SDS + substance list)
- A REACH declaration from the decoration line (process compliance)
- A REACH declaration from the glass manufacturer (substrate compliance)
- A consolidated declaration matching the specific SKU shipped
That last document - the SKU-level consolidated declaration - is the one most manufacturers were not previously producing. Now they need to.
What to ask your manufacturer
Three specific questions cover 90% of what matters:
- "Can you send me the REACH compliance pack for SKU [X]?" If the answer is "what do you mean by pack?" - that's a flag. The correct answer is some version of "yes - that's the ink SDS, the kiln declaration, and the consolidated SKU declaration, attached."
- "Are any of your decoration pigments cadmium, lead, or chromium-VI based?" If the answer is "no, never" - verify with the SDS. The honest answer from most decoration shops in 2024 should be: "we phased these out across our standard palette in 2023; we have one cadmium-based yellow available on special request that we don't ship to the EU."
- "What's your process if an ink supplier reformulates?" Ink chemistry shifts. Pigment manufacturers reformulate quietly. The right answer is: "we get notified of any reformulation through the supplier change-management process, and we re-verify REACH compliance for affected SKUs before continuing production."
The wider point
For decades, regulatory compliance was something the brand owner did and the manufacturer ignored. That model is finishing. Modern decorated glass packaging - for fragrance, candles, cosmetics, food-contact - sits at the intersection of three or four overlapping regulatory regimes (REACH, PPWR, FCM in food contact, individual member-state cosmetic regs), and the documentation burden has shifted upstream.
The manufacturers who'll survive the next five years are the ones treating compliance as a product feature, not a defensive cost centre. The ones who can hand you the declaration pack in 24 hours of your asking will get the repeat orders. The ones who scramble for it across three suppliers and a translator won't.
We've spent the past 18 months rebuilding our internal documentation against the 2024 REACH update. Every SKU we ship from Firozabad to a European warehouse goes with a compliance pack as a default attachment. We think that's table stakes now. We'd recommend asking any prospective supplier to demonstrate the same - and treating the inability to do so as a hard signal.
Need REACH-compliant decorated glass with documentation built in? Start an RFQ - we send the compliance pack with every quote.