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?