Recycle Plastics and EU REACH compliance - under discussion (24.06.13)

재활용 플라스틱에 대한  EU REACH 법령 준수사항에 대한 요약.

 

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Navigating EU REACH Obligations for Recycled Plastics

 

 

 

 

This article provides a comprehensive overview of the potential EU REACH obligations that could apply to recycled plastics, focusing on the “out of waste” regime and monomer registration, which is still under discussion. It addresses key aspects such as determining the point of REACH obligation, understanding the responsibilities of different stakeholders, and navigating the complexities of monomer registration within the EU.

 

Defining the ‘Out of Waste’ Regime

The EU REACH regulation’s application to recycled plastics hinges on the concept of an “out of waste” regime. This regime defines the point at which a recycled material ceases to be considered waste and transitions into a product status. This transition triggers specific REACH obligations.

Criteria for ‘Out of Waste’ Status

; The time of creation of Specific Usage

; existing Market Demand:

; meeting Technical Specifications:

; meeting Product Definition:

; No impact to Environmental and Human:

 

Specific Usage

The recycled plastic must have a defined and intended use. This means there should be a clear application for the material, demonstrating that it’s being utilized for a specific purpose rather than being discarded.

 

Existing Market Demand

There should be a demonstrable demand in the market for the recycled plastic material. This indicates that the material has an economic value and is sought after for specific applications.

 

Technical Specifications

The recycled plastic must meet specific technical requirements and quality standards relevant to its intended application. This ensures that the material is fit for purpose and performs as expected in its intended use.

* Purity and Hazard Profile: The recycled plastic should meet a minimum purity level (e.g., 80%) and undergo hazard profile verification to ensure it doesn’t pose unacceptable risks. This verification involves a thorough analysis of the material’s composition, potentially considering factors such as the presence of substances of concern.

 

Product Definition

Not yet agreed, but the recycled plastic must clearly fall under the definition of a “product” according to EU regulations. This means it should be a distinct and identifiable material intended for a specific use, differentiating it from waste.

 

Obligation Body: Identifying the Responsible Entity

Under the EU REACH framework, the primary responsibility for fulfilling obligations related to recycled plastics often lies with the “owner of the final recovery step.” This typically refers to the entity that performs the last step in the recycling process, transforming the waste plastic into a usable product.

Mechanical Recyclers: This primarily applies to mechanical recyclers, who physically reprocess waste plastics without significantly altering their chemical structure.

Inclusion of PIR and PCR: Both post-industrial recyclates (PIR) and post-consumer recyclates (PCR) fall under this obligation framework.

(Chemical recycling is out of scope. Recycled to chemical means, registration obligation is created where the step of chemical is generated from recycling process.)

 

Industry Guidance for Monomer Registration for general polymers

Industry associations play a crucial role in providing guidance on the “general requirements for monomer registration” for different polymer categories. They offer specific recommendations and standards to ensure consistent and compliant registration practices across the industry.

 

Registration Body Location and Options

The entity responsible for monomer registration must be located within the EU. This could be the manufacturer, importer, or an appointed “only representative.” This requirement ensures a clear point of contact within the EU for regulatory purposes.

(Those who supplies recycled plastics to Europe has two options. Hiring Only Representative in Europe for each substances, or let importer register substances after providing composition information of recycled plastic.)

 

Challenges and Considerations

Implementing and adhering to these potential REACH obligations for recycled plastics present several challenges and considerations for stakeholders across the recycling value chain. Addressing these challenges is essential to ensure compliance and promote the sustainable development of the recycled plastics industry.

 

Traceability and Data Management

Maintaining robust traceability systems throughout the recycling process is crucial. Accurate documentation of material flows, processing steps, and compositional information is essential to demonstrate compliance with REACH requirements.

 

Testing and Analysis

Verification of recycled plastic purity, hazard profiles, and compliance with technical specifications necessitates comprehensive testing and analysis. Investing in reliable testing methods and analytical capabilities is paramount for meeting regulatory standards.

 

Collaboration and Communication

Effective communication and collaboration across the entire value chain, from plastic waste generators to recyclers and users of recycled plastics, are vital. Sharing information, best practices, and addressing challenges collectively can help streamline compliance and promote a more sustainable and circular economy for plastics.

Control of origin of feedstock for recycle will be the key step to communicate potential hazard of recycled plastics. Additionally, when Recycled plastic contains obvious hazard substance, SDS(Safety Data Sheet) writing and providing are also going to be another obligation.

 

Again, it is still under discussion and possible to be changed later.

 

-Fin-