REACH
REACH
CIMA
REACH
REACH regulates obligations regarding chemical substances manufactured, imported or placed on the market in the European Union. Waste as such is not a substance, mixture or article under REACH, but materials recovered or placed on the market as a product may require individual assessment of obligations under REACH.
However, when UPS cease to be waste (EoW) and become a product placed on the market, they are subject to the REACH obligation.
Classic ashes
For selected categories of this type of materials, there is documentation and experience related to REACH requirements. However, this does not mean automatic qualification of every material from every installation. Assessment of obligations requires an analysis of the composition, legal status, method of marketing and planned use.
If they are considered a by-product or obtain end-of-waste status and are placed on the market as a raw material for concrete/cement or aggregate, the REACH obligations for the material in question (most often as mixtures/UVCB) must be assessed.
In practice, it is essential to demonstrate stable composition, predictable use, and safety of use in the supply chain.
SDA (Semi-Dry Absorption products)
For selected categories of this type of materials, there is documentation and experience related to REACH requirements. However, this does not mean automatic qualification of every material from every installation. Assessment of obligations requires an analysis of the composition, legal status, method of marketing and planned use.
If SDAs are used as secondary raw materials (e.g., as a component of binders, soil stabilization), their status must be clearly defined: waste / by-product / EoW.
When placing on the market, it is necessary to analyze them in terms of REACH (e.g., whether the material is a UVCB substance or a mixture with unused calcium sorbent). The most important thing is to document the repeatability of quality and the absence of environmental and health risks.
Fluidized bed ash
For selected categories of this type of materials, there is documentation and experience related to REACH requirements. However, this does not mean automatic qualification of every material from every installation. Assessment of obligations requires an analysis of the composition, legal status, method of marketing and planned use.
After going through the by-product or end-of-waste path and when sold as a raw material (e.g., for binders, geotechnics, reclamation), they are subject to REACH. The following factors are important in the REACH assessment: higher calcium/sulfate content, possible reactivity, and whether the material is sold “on its own” or as a component of a final product covered by other standards.
Biomass ash
For selected categories of this type of materials, there is documentation and experience related to REACH requirements. However, this does not mean automatic qualification of every material from every installation. Assessment of obligations requires an analysis of the composition, legal status, method of marketing and planned use.
When marketed as a secondary raw material (e.g., a component of binders or, in selected fractions, a fertilizer product), it is necessary to check REACH obligations, especially when the ash is offered as a stand-alone product.
For biomass ash, it is important to consider the variability of its composition (depending on the type of biomass and combustion) and to assess any inorganic contaminants that may affect classification and information requirements in the supply chain.
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