When a substance appears on the SVHC Candidate List, a supplier of articles that contain this substance should inform his customers to allow safe use of articles, at least by providing the name of the substance concerned. How should this information be given? Can it be done by means of a line on the order confirmation for newly bought, concerned articles, eventually referring to a letter providing more information? Or should also customers who have bought these articles in the past (before the substance was mentioned on the list) be informed?

a)  A company which buy polymers -raw materials in pellets bought from a petroquemical- in Europe, so the pellet is reach complied. The company mixes the pellet (may be from diferents raw material supplyers) with black carbon or masterbatch. And sells the compound to the converter.

Which is the obligation regarding reach? 

Has this company to get a SDS from every supplier? for make sure the raw materials polymers and the additives are comply. 

has this company to prepare a new SDS about their own compound?

b) A recicler company who recycles post consumer plastic waste into recycled plastic material. But the plastic waste is PET bottles made in Europe, so is an article put in the market with the compliment of reach.

So, the product sold by the company is recycled polymer, but as it is from bottles made in UE, has in any case the obligation to prepare the SDS-R?' of the material? Where can I find the SDS-R template or information about this?

REACH & Recycling, use of substances in the past now on concept authorisation list

Substances that were used in the plastic industry in the past frequently like HBCDD (flameretardant) and certain phtalates, are listed on the concept authorisation list. Will this have consequences for the recycling industry when these substances definitive need authorisation ? Is the recycling industry still allowed to recycle plastics that possibly contain these substances

As an importer of polymer from non EU teritory i need to register the monomer(s) as far as not done by the manufaturer or an (his) only representative.

Having pre-registered the monomers but not received any response from a pre-SIEF, one does`nt know, how to find the respective SIEF(s) and their contact addresses.

Question: How to find/contact the respective SIEFs ? Just by following the pre-registration in REACH-IT or is there any other possibility to find ?

Will REACH Club organize more webinars in 2010? When?

Are EU resin manufacturers required to receive use-identification from non-EU converters?  If they are required to do so, should the converter pro-actively submit or wait for the resin manufacturer to make contact?

How, if at all, will REACH be enforced for articles?  Some of our importers are asking if they will be required to present "REACH documents" for customs release.  If there will be checks of imported articles what will be considered acceptable documentation?  Will a printed statement from the manufacturer that the article does not include substances that require notification (SVHC or intended for release) be accepted?

A company which chops plastic pipes into pieces removes the metal and sells it to plastic converter. The plastic converter manufactures plastic pipes again. Does the company sell waste or recovered material ?

The introductory Chapter 1 of the guidance waste and recovered substances addresses the concepts of waste under REACH and the borderline between waste and material that has ceased to be waste.

However in this guidance does not clarify the definition of waste or recovered substance for me.

According to Article 6 (1) and (2) of the new Waste Framework Directive, certain specified waste shall cease to be waste when it has undergone a recovery operation and complies with specific criteria to be developed in line with certain legal conditions, in particular:

(a) the substance or object is commonly used for specific purposes;

(b) a market or demand exists for such a substance or object;

(c) the substance or object fulfils the technical requirements for the specific purposes and meets the existing legislation and standards applicable to products; and

(d) the use of the substance or object will not lead to overall adverse environmental or human health impacts.

1) Recycled plastics with no new substances added by the recycler but containing "SVHC on the candidate list" (e.g. DEHP) above 0.1% w/w. Example recycled PVC with 0.2% DEHP after te recycling process. Is the "SVHC on the CL' in the recycled plastic an "impurity" in the recycled plastic? See definition of substance: - Process = recycling process. - Impurity is part of the substance according to substance definition. When a plastic converter uses the recycled plastic without adding hismself the same "SVHC on the candidate list (e.g. DEHP)", does Art 33 (communication obligation) apply?

2) Is there already a draft or official ECHA publication that answers questions about REACH, plastic waste and recycled materials?