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?

Is there any guidance available, or intention to develop a standard questionnaire, that we can use when purchasing recycled material in order to ensure compliant and safe use under REACH? Is the following sufficient?

We need to understand the composition of the recyclate in order to be on the safe side of REACH :

-         We need to know the source of the material so that we are confident it does not contain any SVHC (art. 2.7.d àart.32.1.b)

-         It should not contain substances subject to authorization or to restrictions (art. 2.7.d àart.32.1.b+c)

-         The supplier (recycler) needs to confirm that he pre-registered the substances (or monomers in case of polymers) in the recyclate (art 28.1). This is required in order to bridge the gap between end of pre-registration phase and date of registration.

-         After 1 Dec 2010 he needs to be able to provide us with a SDS for the recovered material and with necessary RMM if needed (art. 27.d àart.32.1.d). However if it does not contain any hazardous material it is not needed.

This needs to be confirmed in writing by supplier. I have also seen statements on analysis, do we need to go that far?

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?