New Pilot Project Report Finds Many Waste-Recovered Substances Not in Compliance with REACH
The Forum for Exchange of Information on Enforcement of the European Chemicals Agency (ECHA) recently released its report on a pilot project that looked at recovered substances that are exempted from REACH registration requirements. In this blog post, we review several of the key project findings relative to REACH Article 2(7)(d) compliance.
CPilot Project
The pilot project was conducted in 11 European Economic Area countries: Belgium, Czech Republic, Denmark, Estonia, France, Germany, the Netherlands, Norway, Portugal, Romania, and Spain. An important focus of the project was the evaluation of compliance with REACH Article 2(7)(d) as it relates to exemptions from REACH registration obligations for recovered substances (those that have lost their status of “waste”). This evaluation was conducted in 46 cases.
According to Article 2(7)(d) of REACH, exemptions from registration for recovered substances are provided if:
- (i) the substance that results from the recovery process is the same as the substance that has been registered in accordance with Title II;
- (ii) the information required by Articles 31 or 32 relating to the substance that has been registered in accordance with Title II is available to the establishment undertaking the recovery.
Relative to REACH Article 2(7)(d)(i)
- 63% of the cases (29 of them) were found to be in compliance with REACH Article 2(7)(d)(i)
- It was determined that they could be the same as an already registered substance
- 26% of the cases (12 of them) were found to be non-compliant with REACH Article 2(7)(d)(i)
- It was determined that they could not be the same as an already registered substance
- 11% of the cases (5 of them) could not be found to be compliant or non-compliant with REACH Article 2(7)(d)(i)
- Identification of the substance could not easily be determined
- 63% of the cases (29 of them) were found to be in compliance with REACH Article 2(7)(d)(i)
Relative to REACH Article 2(7)(d)(ii)
- 96% of these (44 cases) were found to be in compliance with REACH Article 2(7)(d)(ii)
- Inspectors were provided with required information to make this determination
- 4% of these (2 cases) could not be found to be compliant or non-compliant with REACH Article 2(7)(d)(ii)
- Information was not clear enough to make a definitive compliance determination
- 96% of these (44 cases) were found to be in compliance with REACH Article 2(7)(d)(ii)
The pilot project is a significant step toward facilitating cooperative efforts between various waste authorities and REACH. It also represents an important step toward improving future chemical legislation enforcement. More detailed information about the project, its underlying objectives, and other relevant findings may be found by reviewing the corresponding report.
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