Posted on 04/11/2008 in category Environment




Brussels,4 November 2008

BIRAutumn Round-Table Sessions

Düsseldorf,30-31 October 2008

InternationalEnvironment Council:

REAChand its implications for the recycling industry

OlivierFrançois of Galloo Group is taking up the chairmanship of BIR’sInternational Environment Council (IEC) at a highly promising momentin time for the recycling industry, he confirmed to delegates inDüsseldorf. The new EU Waste Framework Directive “gives us thepossibility to have a view on end-of-waste status (for recyclables)after 30 years of effort”, he declared. “If end-of-waste statusis available in the medium term, it will mean we are sellingsubstances.”

TheIEC meeting was subsequently devoted almost entirely to the EU’sregulation on the Registration, Evaluation and Authorisation ofChemicals (REACh), theaim of which is to make persons placing chemicals on the marketresponsible for understanding and managing the risks associated withtheir use. MrFrançois underlined the importance to recyclers of pre-registeringtheir substances with the European Chemicals Agency (ECHA) byDecember 1 2008. “We have to be on the safe side,” he explained.“This will give us two years to prepare for the future.”

Chemicalsubstances on their own, in preparations and those which areintentionally released from articles must be registered with theECHA. The regulation applies to substances manufactured in, orimported to, the EU in annual quantities of 1 tonne or more percompany, unless the regulation indicates otherwise.

TheEuropean Commission has recently reiterated the need to pre-registerrecovered substances that have ceased to be waste under the EU’sREACh regulation by the start of next month. Companies whopre-register their substances can benefit from the extendedregistration deadlines noted by Mr François.

REAChprovides relief for recyclers by exempting from registrationrecovered substances that have been registered before. But sincethere is no certainty that registrations would have already beencompleted by December 1 this year, final recovery installations arebeing advised to pre-register their manufactured substances in orderto cover their activities until registration of those substances hastaken place.

Pre-registrationis a simple, free-of-charge procedure and requires provision of onlylimited data such as contact details, name of substance and tonnageband, it was stressed in Düsseldorf by guest speaker Kees Wielengaof Netherlands-based FFact Management Consultants. And he urgedrecyclers not to wait until the final available day beforepre-registering because website access could be slow.

DrOtto Linher, Head of Sector at Unit G.1 REACh within the EuropeanCommission’s DG Enterprise and Industry, used his own guest speechand a subsequent question-and-answer session to tackle some of thecomplex issues surrounding this regulation. In terms of specificmaterials, he noted that pure metals such as iron are substancesunder REACh even if containing impurities, whereas alloys willnormally be regarded as preparations.