REACH Statement

                                              REACH statement

                                               September, 2022  

In the REACH Regulation, a recovered material is considered a substance which
has ceased to be waste and REACH requirements apply.

For recovered substances, Article 2(7)(d) provides exemption from REACH
registration requirements if the same substance has already been registered at
the manufacturing stage and information on the registered substance is
available.

Rubber recyclers are therefore exempted from the obligation to register the
monomer(s) and any chemically bound substance(s), provided that they have
been registered and data is available.

Rubber Resources checked the registration of all polymer-derived monomers,
constituents present in quantities over 20% and any other substance which still
plays an intended role in the recycled rubber. We concluded that all the
necessary information is available.
Based on these two findings, Rubber Resources fulfils the conditions described in
Article 2(7)(d) and is thus exempted from REACH registration requirements.

This covers all our recycled products which are therefore REACH compliant. This
includes all grades of butyl reclaim (RBR), natural rubber reclaim (RNR), truck
tire reclaim (RTT) and curing bladder reclaim (RCR).

According to Article 2(7)(d), Rubber Resources is not required to register the
recovered substances, neither to make an exposure scenario for the downstream
uses nor to notify the use of the recovered substances, even if the use of the
recycled rubber is not mentioned in the SDS of the substance at the
manufacturing stage.

Rubber Resources will supply the necessary information by providing an SDS. For
recycled materials, an SDS may be compiled using generic information and does
not require notification of a registration number or an exposure scenario.

Rubber Resources is aware of the notification obligations for substances included
on the Candidate List as described in Article 33 and will inform customers where
necessary.

Rubber Resources is determined to be REACH compliant at all times. If new
obligations for the recycling industry are introduced in the future, we will respond
accordingly.

REACH representative for Rubber Resources:

Mrs. Anita Hendriks
Email: a.hendriks@rubber-resources.com
T: +31 (0)43 329 0366

Downloads

REACH statement