Chemicals are present in nearly every product and process in modern life – from industrial manufacturing to everyday items like electronics, textiles, and furniture. The EU’s REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals) plays a central role in ensuring that these substances are safely used, protecting both human health and the environment.

As REACH applies to all chemical substances, including those found in recovered materials, it has significant implications for the recycling industry. This means that recyclers, although not the original producers of the substances and usually not adding any new ones, are requested to navigate complex and costly obligations. Ahead of the upcoming REACH revision, it is crucial to ensure that EU regulation, in the quest of protecting human health and the environment, does not hinder the transition to a circular economy. Overly restrictive or unclear chemical rules can unintentionally hinder recycling, limit the use of secondary raw materials, and ultimately undermine EU ambitions on resource efficiency, circularity, and strategic autonomy.

As part of its first 100 days, the von der Leyen Commission launched the Clean Industrial Deal to strengthen Europe’s industrial competitiveness while achieving climate neutrality by 2050 and making the EU a circular economy leader by 2030. A key part of this plan is the Chemicals Industry Package, which includes simplifying REACH and addressing “forever chemicals.” During the April CARACAL meeting, the Commission clarified that the goal of revising REACH is not deregulation but reducing administrative burden.

To ensure the REACH revision supports both circularity and the protection of human health and the environment, EuRIC – the European Recycling Industries’ Confederation – outlines key recommendations for a targeted and balanced revision.

EuRIC calls for:

Clear rules for recycled raw materials: Allow comprehensive and timely derogations (exemptions) for recycled materials, articles made from recycled materials and reused materials when restrictions are applied, to allow for the depuration of waste streams without scaling down circular economy ambitions.

No excessive burden for polymers registration: Avoid creating a mandatory list of polymers requiring registration (PRR), which would add unnecessary administrative burdens on recycled materials.

Avoid hazard-only approaches in favor of a risk-based approach: Grouping and banning substances based exclusively on hazard classes without considering potential exposure, limits their use in safe applications and reduces the potential of recycled materials without a significant impact in the protection of human health and environment. Moreover, expanding Generic Risk Management (GRM) to professional use risks overlapping with workplace safety legislation, leading to double regulation.

Standardisation of analytical methods in the EU: EU regulators should ensure that analytical methods are validated and standardised across the EU to guarantee their transferability between testing facilities.

Transparency requirements for digital information tools: The digitalisation of the tools to transmit information across the value chain will only achieve their intended purpose if the information they contain is complete and reliable.