REACH Regulation and Circular Economy Guideline is now available

12 Oct, 2023

In order to promote circular economy, the concepts of ‘by-product’ and ‘End-of-Waste’ are highly relevant. REACH does not apply to waste. But REACH does apply to by-products and end-of-waste. According to the Waste Framework Directive, a material can only achieve a by-product or end-of-waste status if it complies with applicable legislation and standards, one of which is REACH. Therefore REACH is highly relevant for the circular economy: in principle any secondary raw material that can (potentially) be regarded as by-product or as end-of-waste may need a REACH registration in order to achieve the by-product or end-of-waste status. Sometimes an authorisation may be required and restrictions may apply. There are however some exemptions to these obligations. 

Therefore, a clarification about the applicability of REACH to the aforementioned is essential to promote their market and circulation. 

This report aims to offer guidelines for applying REACH in the circular economy. To elaborate on the theme, it includes multiple practical examples from different Member States.   

The report is divided in 6 chapters and 2 annexes:  

  • Chapter 1 introduces the theme and describes the most important basic concepts of REACH Regulation.  
  • Chapter 2 examines the scope of application of REACH Regulation and how it might apply to waste-based materials.  
  • Chapter 3 describes other relevant chemicals legislation which might be applied to waste-based materials. These provisions are not focused on in this report focusing on REACH Regulation.  
  • Chapter 4 provides guidance with practical examples to interpret and comply with the basic obligations of REACH Regulation: Registration, authorisation and restrictions.  
  • Chapter 5 provides guidance on applying the exemptions from the basic provisions of REACH. The chapter includes a subchapter focusing on applying recovery exemption to recycled plastics.  
  • Chapter 6 discusses the enforcement of REACH Regulation in recovery plants.  
  • Annex I contains a flowchart for REACH compliance summarizing the basic content of this report.  

Annex II sets out checklist for chemicals legislation compliance.  

REACH Regulation and Circular Economy Guideline is now available also on Waste Management and Circular Economy Project page



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