Posted on 17/11/2008 in category Environment

Bureau of International Recycling

Theworld federation of recycling industries


HaveEU New-Scrap importers Pre-registered with REACh yet?

As the window of opportunityfor companies to pre-register will close in 13 days time, BIR is concerned thatworldwide trade into the EUcould in future be constrained as few EU based scrap importers arepre-registering with REACh.

BIR’sbest advice to EU based companies that are importing scrap from outsidethe EUis as follows:

[1] EU based companies,such as metal-works, foundries, scrap yards and traders, that areimportingfrom outside the EU New Scrap of either non-ferrous or ferrous metalsshould seriouslyconsider to pre-register those metals and their wanted alloyingelements by 1December 2008. Whilst there is apparently no legal requirement topre-register,Companies that have pre-registered will most likely have a commercialadvantagein ability to import in the future, otherwise access secondary rawmaterialsfrom outside the EU, over those that have not.

[2] EU based companies,such as metal-works, foundries, scrap yards and traders, that areimportingfrom outside the EU Fully Processed Old Scrap, i.e. ready to melt OldScrap ofeither non-ferrous or ferrous metals should consider to pre-registerthosemetals and their wanted alloying elements by 1 December 2008. Whilstthere isapparently no legal requirement to Pre-register, Companies that havepre-registered will likely have a commercial advantage in ability toimport inthe future, otherwise access secondary raw materials from outside theEU, overthose that have not.

BIRhas added to its web-page from the ECHA REACh FAQ especially relevant to traders, conclusions from that advice and theregulationREACh itself are that:

[A] A trader outside theEU exporting to the EU is not a manufacturer and so can neitherpre-register /register substances in REACh nor appoint an "Only Representative".

[B] A trader inside theEU importing substances into the EU will need to pre-register thosemetals andtheir wanted alloying elements by 1 December 2008, a trader importingNew Scrapor fully processed Old Scrap, i.e. ready to melt Old Scrap of eithernon-ferrous or ferrous metals should seriously considerpre-registration.


For EU based companiespre-registration is easy, it is free and simple, it may take less thanan hourto comply through the on-line registration system, however theopportunity toPre-register closes in some 13 days time.

Pre-registration requiresonly limited data and there is no fee associated to it. On-linepre-registration entails, in its simplest form, entering the requiredinformation directly into the REACH-IT system [].The European Chemicals Agency (ECHA) provides the following trainingmaterialhere []on how to submit pre-registrations on different type of substances viatheREACH-IT portal


Apre-registration file for a substance consists of:

 Substance Identity:EINECS number, CAS numbers and names of the substance e.g. for thesubstancename "Copper" the EINECS number, EC# is 231-159-6; the CAS# is7440-50-8 [Search EINECS and CAS# on the website]

Here is a list of mostlikely Metals and wanted alloying elements to Pre-register are:-



Envisageddeadline and tonnage band for the registration

(Manufacturing or importtonnages bands are: > 1 tonne per year; 100 to 1000 tpy;>1000 tpy. Forwhich different registration deadlines apply as: 1st December 2010; 1stJune2013; 1st June 2018.)

Name andcontact information of a contact personor third partyRepresentative who will act as the contact point in data sharing

On-line pre-registrationentails, in its simplest form, entering the required informationdirectly intothe REACH-IT system [].

The information above isfurther elaborated on the BIRwebpage

Whilst much relief fromREACh requirements have been gained for EU based enterprisers that arecurrently operating under the EU waste legislation and collecting,sorting andprocessing scrap from within the EU, BIRadvises specifically that EU based scrap importing companies should,apart fromthe legal question of Pre-Registration relevant to their status andactivity,assess pre-registration as a precautionary business decision that canensureunder changing circumstances an enterprises' ability to import metalscrap fromoutside the EU.


For furtherinformation pleasecontact …
Ross Bartley
Environment andTechnical Director
Avenue FranklinRoosevelt 24
1050 Brussels,Belgium
Tel +32 2 62757 70, Fax +32 2 627 57 73