REACH for plastics recyclers
The European Community Regulation on chemicals and their safe use (REACH)
Does REACH apply to plastics recyclers?
Yes, all forms of recovery including mechanical processing whenever they result in one or more substances as such or in a mixture or in an article that have ceased to be waste after one or more recovery steps are considered as a manufacturing process. Thus, plastics recyclers must comply with the REACH obligations of Manufacturers (for Substances and Mixtures) or Article Manufacturers if they make themselves an Article directly out of the waste.
What are the plastics recyclers’ obligations under REACH?
Beside the exemption to register substances (Article 2.7.d.) recyclers have to apply all the other obligations. In short they must provide Safety Data Sheets (SDS), apply CLP Notification and comply with Restrictions and Authorisations if they are substances/mixtures manufacturers. If they make Articles, they have to apply the relevant Registration, Notification and Information obligations.
How can plastics recyclers make SDS?
PRE, EuPC, PlasticsEurope and Vinyl 2010 have created a tool providing REACH compliant tailor-made generic Safety Data Sheets. You can find more information on www.sdsrtool.com.
For more information about SDS-R tool click here.
Who can advise me on REACH?
PRE in collaboration with the Polymer Comply Europe (http://www.polymercomplyeurope.eu/what-we-do/regulatory-compliance) provide a tailor made service in order to audit the recycler’s compliance with this Regulation. Contact us to get an efficient support and please do so immediately if you are informed that you will be inspected by your National Competent Authority