EuRIC Reaction to the Inception Impact Assessment on the revision of EU legislation on REACH

The European Recycling Industries’ Confederation (EuRIC) welcomes the Inception Impact Assessment on the revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH) and its main objective to transition towards a clean Circular Economy. Bridging the various phases of products’ life cycle in relation to chemicals to achieve safe products and non-toxic material cycles, including through substitution, is of paramount importance to support a safe circular economy, given the lasting problems posed by legacy substances at recycling stage, regardless of the separation and sorting technologies used for material recovery purposes and streams at stake (WEEE, packaging, ELVs, tyres, textiles, batteries, etc.).

EuRIC finds the problem that the above initiative aims to tackle very relevant not only for downstream users of chemicals but also for companies who recycle – a large number of small, medium and large enterprises scattered across the EU whose role in the Circular Economy journey is considered of an utmost importance.

Thus, the top priorities identified by EuRIC – which will further ameliorate the aforementioned legislative framework - can be found in this paper.

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