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Waste Laws

Helping Recyclers meet EU End-of-Waste Rules

Please take the time to read the referenced documents. You will likely find that your company is carrying out some of the necessary procedures already.

1. Comply with the applicable End-of-Waste Regulation
The Council Regulation (EU) N° 333/2011 establishing criteria determining when iron, steel and aluminium scrap including aluminium alloy cease to be waste.
Download the Regulation in your prefered language:

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Council Regulation (EU) N° 333/2011 sets the criteria scrap producers must meet, including:

  1. the implementation of a Quality Management System. The Bureau of International Recycling provides its guide on how to implement a QMS which includes the required documented procedures.
    (download at http://www.bir.org/publications/tools- for-qm/)

  2. the Statement of Conformity. For each consignment of scrap (a consignment may be contained in either one or several transport units, such as containers) a statement of conformity must be issued, it may be in electronic form.


2. Comply with REACh

Having met the criteria for end-of-waste, produced scrap has to comply with the product legislation REACh. REACh conditionally exempts recovered substances in Article 2.7(d).
Articles 31 and 32 explain about safety information. Further explanations for recyclers are provided in the European Chemicals Agency’s “Guidance on waste and recovered substances”. To meet these conditions, recyclers need:

  1. To be able to explain how the recovered substance is the same as the substance that has been registered (download sameness document for aluminium alloys here)

  2. To have available Safety Information from ECHA website http://apps.echa.europa.eu/registered/registered-sub.aspx#search. Insert the CAS number (copy from list here) to view safety information from the ECHA website (example below)



  3. To provide Safety Information to your customer, you may use the safety information below after adding your company contact details to the document you give to your customer:

    - Safety Information documents: Aluminium; Copper; Lead; Zinc; Nickel; Tin
    - Safety Information Sheets under development Aluminium; Copper

It is recommended that the contract records the customer’s acceptance of scrap classified as product.

 

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REACh Regulation (EC) No 1907/2006

Article 2 : Application
7. The following shall be exempted from Titles II, V and VI: (d) substances, on their own, in preparations or in articles, which have been registered in accordance with Title II and which are recovered in the Community if:
(i) the substance that results from the recovery process is the same as the substance that has been registered in accordance with Title II; and
(ii) the information required by Articles 31 or 32 relating to the substance that has been registered in accordance with Title II is available to the establishment undertaking the recovery.

REACh Regulation (EC) No 1907/2006

Article 2 : Application
7. The following shall be exempted from Titles II, V and VI: (d) substances, on their own, in preparations or in articles, which have been registered in accordance with Title II and which are recovered in the Community if:
(i) the substance that results from the recovery process is the same as the substance that has been registered in accordance with Title II; and
(ii) the information required by Articles 31 or 32 relating to the substance that has been registered in accordance with Title II is available to the establishment undertaking the recovery.