Waste reprocessors that transform waste into chemicals need to understand what chemicals they are selling and the composition of materials they are recycling to ensure they comply with the registration, evaluation, authorisation and restrictions of chemicals regulation, warned an industry expert.
The REACH regulation, which became fully operational in the UK in June 2008, applies to recovered waste once the chemicals have been recovered and purified from the waste and it officially ceases to be waste under the EU Waste Directive. Waste itself as defined by the Waste Framework Directive is excluded from REACH by not being classified as a substance.
This can affect battery firms transforming waste into chemical substances.
BMT is a consultancy that offers clients advice on the REACH regulations. Principal consultant Nikki Robinson said: The main key issue with REACH is communication and reprocessors need to understand what they are recycling and what materials they take in for recycling and what they are composed of. A lot of this has been covered by the Waste Framework Directive. But the reprocesssor needs to know what chemicals they are selling and composition of materials they are recycling.
There needs to be communication up the supply chain to ensure that organisations meet the requirements of the REACH regulations and register their products under the regulations. Companies need to register with the European Chemicals Agency in Helsinki.
Last month, BMT REACH representative services head Damien Carson told MRW that companies that continued to market their chemicals in the EU that were not pre-registered or registered would face fines if they failed to comply (see MRW story). Each chemical must be pre-registered and/or registered by each company manufacturing or importing this chemical in the EU in excess of one tonne per year. Each firm is then required to submit a full registration unless they intend to terminate manufacture or import after the relevant deadline has been reached in 2012/13/18.
Robinson acknowledged why firms might find the REACH regulations difficult to understand. He said: The REACH legislation is a massive bit of legislation. It composes of 40 previous bits of legislation and is 900 pages long it is a very ambitious piece of legislation.