Many recyclers who manufacture or import do not realise they could face enforcement action if they have not pre-registered their recovered substances.
Registration, Evaluation and Authorisation of Chemicals (REACH) regulations came into force in 2007 asking for recyclers which import above one tonne per legal entity or manufacture to pre-register any in-scope chemicals present in its recovered materials.
Experts in the field REACHReady spoke of its concern at the RWM exhibition that many firms may be subject to enforcement action if they missed the six-month pre-registration phase in 2008. The Health and Safety Executive has already begun taking action against non-compliant companies.
Director Joanne Lloyd believes the problem has been caused by a lack of awareness in the sector, as recyclers do not realise that they come under the chemicals bracket. She said: We are here today because at our help desk we are getting lots of calls from people like yourselves who are just finding out about REACH. You might have missed the boat for the purposes of pre-registration but that doesnt mean to say you should sit there and do nothing.
Firms need to deal with this as a business process going forward because if you cant prove you are compliant with REACH the chances are your customers will stop buying from you in future. Start looking at REACH now to find out where your obligations are.
Metals recyclers must comply as metals and alloys are classed as chemicals under the legislation and recovered aggregates recyclers which buy the waste for its chemical composition also need to comply. Firms which deal with recovered polymers such as plastic bottle recyclers should have pre-registered the monomer that the polymer stems from rather than the polymer itself.
Firms in breach of REACH are given a compliance notice in which they must take steps to comply and there is a possibility of being fined, although this has not yet happened. If firms fail to register they could be shut down or put in prison.
Full registration of the chemicals begins in 2010 for many firms, although there are several deadlines reaching 2018 and beyond.