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?