PRE in collaboration with the Polymer Comply Europe provide a tailor made service in order to audit the recycler’s compliance with this Regulation. Contact us to get an efficient support and please do so immediately if you are informed that you will be inspected by your National Competent Authority.
Yes, all forms of recovery including mechanical processing, whenever they result in one or more substances as such, in a mixture, or in an article that have ceased to be waste, after one or more recovery steps are considered as a manufacturing process. Thus, plastics recyclers must comply with the REACH obligations of Manufacturers (for Substances and Mixtures) or Article Manufacturers if they make themselves an article directly out of the waste.
Beside the exemption to register substances (Article 2.7.d.) recyclers have to apply all the other obligations. In short, they must provide Safety Data Sheets (SDS), apply CLP Notification and comply with Restrictions and Authorisations if they are substances/mixtures manufacturers. If they make Articles, they have to apply the relevant Registration, Notification and Information obligations.
PRE, EuPC, PlasticsEurope and Vinyl 2010 have created a tool providing REACH compliant tailor-made generic Safety Data Sheets. You can find more information on