REACH, the European Union regulation for the Registration, Evaluation and Authorisation of Chemicals, entered into force on 1 June 2007, and has had a major impact on manufacturing supply chains, the recycling and recovery industry being no exception. Recovery businesses are considered to be manufacturers under REACH, and may have registration obligations, unless they can demonstrate that certain exemptions apply to them.
The good news is that waste itself, as defined by the Waste Framework Directive (WFD, 2008/98/EC), is excluded from REACH as it is classed as something other than a substance, a mixture or an article. However, once waste is recovered into a substance, a mixture or an article it ceases to fall under the provisions of the WFD and falls into the scope of REACH.
Often, defining the point at which waste ceases to be waste and becomes a recovered substance is not trivial, but it is at this point waste management controls no longer apply and REACH takes over. Waste legislation will help you decide whether you are dealing with waste, or whether you have in fact recovered chemical substances – making you a manufacturer in the eyes of REACH.
REACHReady’s aim is to help our subscribers help themselves achieve compliance. A plethora of guidance and articles about REACH and CLP can make it all seem more complicated and difficult than it is, so much of what we do is to remove some of the mystery and fear. We want ...
