One quarter of all recycled substances and mixtures do not meet the requirements of REACH, according to a study undertaken as part of an ECHA enforcement project. In the project, inspectors performed 46 examinations in 11 countries of the European Economic Area. In 12 cases, management of the waste operators was unable to provide analytical data and prove that the recycled substances were identical to substances already registered under REACH. However, that is exactly what Article 2(7)(d) of REACH requires.
And the CLP Regulation was not followed in 7 of 19 of the examinations. According to Article 40 of the CLP Regulation, waste operators are obligated to provide the ECHA with information on the recycled substances. The inspectors state that this obligation was not fulfilled.
In their closing report, the authors recommend that the national agencies responsible for implementation of REACH and the Waste Framework Directive improve their collaboration in the future and supervise observance of the regulations more closely.
If you have any questions about the REACH and CLP regulations, please contact firstname.lastname@example.org.