Deinkers’ soaps stay out of the reach of REACH:

No soap registration needed for paper recycling


The soaps produced and used in the deinking process do not have to be registered within the REACH process. This has been confirmed to INGEDE by the German Federal Institute for Occupational Safety and Health (BAuA). In a recent statement regarding the release of Commission Regulation (EC) 987/2008, Claus Haas of BAuA states that "according to Annex V in accordance with Article 2(7)(b) certain fatty acids with an alkyl chain length between C6 and C24 obtained from natural sources as well as their sodium, potassium, calcium, and magnesium salts do not have to be registered according to REACH Directive (EC) 1907/2006 if they have not been chemically modified."

In general, all chemical substances exceeding one ton per year used in a production process have to be registered. Several rules and exemptions apply e. g. for non-isolated process intermediates, certain uses, and certain substances. Annex IV lists "well-known substances" like oils and a number of fatty acids. Annex V lists substances for which registration would be inappropriate like naturally occurring substances.  

INGEDE succeeded in convincing CEPI that the registration of soaps is not needed and that there had been contradictions in the REACH annexes. Now the EC has changed the Annexes IV and V. Still the wording in the Annex V left some small uncertainties. INGEDE has therefore asked the German REACH helpdesk for an official statement for its members.

Click here for the full text of the answer (German)
and here for the English translation.

The CEPI soap working group, where INGEDE took the leading part, will also distribute this information and will inform the CEPI REACH implementation issue group.

Recovered paper also exempt from registration

Recovered Paper and the sorting of "waste" paper also seems to be out of the reach of REACH. Recovered paper can be defined as cellulose fibre material listed in Annex IV.

At a conference on October 30th in Düsseldorf, Otto Linher of the European Commission, DG Enterprise, towards the German Association for Secondary Raw Materials and Waste Disposal (bvse) expressly pointed out that recovered paper does not have to be registered (source: bvse press release).

Another possibility to handle recovered paper is to define it as waste according to the draft of the EU waste regulation until it is pulped. That way the waste status ends with the use of recovered paper in the paper mill. The German Federal Environmental Agency (UBA) recommends this approach.

Draft guidance on REACH Annex V exemptions

The European Commission has taken the unusual step of publishing a draft guidance document to further explain Annex V of the REACH Regulation only a few days after the publication of the changes in the annex. This guidance can be downloaded here.

Pre-registering of process waste needed?
The German Paper Industry Association (VDP) recommends to register sludge and ashes!

All residues of the deinking process can be classified as waste. All kinds of waste are exempt from REACH. Biogas produced in the mill is an exemption according to Annex V. If the residues leave the mill as waste rather than as substance, there is no need for registration.

Still it could be of advantage in the long run to pre-register ash and sludge in order to keep all possibilities open. Then no problems will occur in marketing the residues as substances if such a possibility comes up in the future.

VDP recently recommended this practice to its members.

Please contact VDP (Dr. Thiel) or your local association for support.

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