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DaiJones  
#1 Posted : 29 September 2021 07:17:11(UTC)
Rank: New forum user
DaiJones

Hi All

My business imports plastic pellets from Europe for our extrusion process. I am getting questions about Reach that i have never had before and where i think i understand it i thought best to ask some experts. 

Simple question my feeling is REACH won’t apply to plastic pellets but does it? 

Thanks

Dai 

Roundtuit  
#2 Posted : 29 September 2021 08:52:07(UTC)
Rank: Super forum user
Roundtuit

REACH applies to everything. As plastic pellets the primary constituent would likely be considered a polymer and so excluded from most duties under REACH.

What you do need to consider carefully though are the substances contained in these articles - the pigments. fillers, extenders, plasticisers, functional additives (e.g. flow modifiers, flame retardants...)

Any candidate Substances of Very High Concern? If so what w/w percentage? What annual tonnage?

https://echa.europa.eu/regulations/reach/candidate-list-substances-in-articles

https://www.hse.gov.uk/reach/substance-in-articles-notification.htm

Any substances subject to authorisation (a number of fire resistant chemicals are now withdrawn from use having ended their authorisation period)

Any substances subject to restriction (most phthalate plasticisers are banned from child care products)

https://echa.europa.eu/substances-restricted-under-reach

thanks 4 users thanked Roundtuit for this useful post.
peter gotch on 29/09/2021(UTC), DaiJones on 01/10/2021(UTC), peter gotch on 29/09/2021(UTC), DaiJones on 01/10/2021(UTC)
Roundtuit  
#3 Posted : 29 September 2021 08:52:07(UTC)
Rank: Super forum user
Roundtuit

REACH applies to everything. As plastic pellets the primary constituent would likely be considered a polymer and so excluded from most duties under REACH.

What you do need to consider carefully though are the substances contained in these articles - the pigments. fillers, extenders, plasticisers, functional additives (e.g. flow modifiers, flame retardants...)

Any candidate Substances of Very High Concern? If so what w/w percentage? What annual tonnage?

https://echa.europa.eu/regulations/reach/candidate-list-substances-in-articles

https://www.hse.gov.uk/reach/substance-in-articles-notification.htm

Any substances subject to authorisation (a number of fire resistant chemicals are now withdrawn from use having ended their authorisation period)

Any substances subject to restriction (most phthalate plasticisers are banned from child care products)

https://echa.europa.eu/substances-restricted-under-reach

thanks 4 users thanked Roundtuit for this useful post.
peter gotch on 29/09/2021(UTC), DaiJones on 01/10/2021(UTC), peter gotch on 29/09/2021(UTC), DaiJones on 01/10/2021(UTC)
CptBeaky  
#4 Posted : 29 September 2021 08:58:18(UTC)
Rank: Super forum user
CptBeaky

As an aside, in 2019 (as I recall) there was a consultation around the pollutant risks of the pellets. This was mostly surrounding their clasification as a "micro plastic" and they were considered low hanging fruit in a drive to reducing pollution in that area. I am not sure as to the results of that consultation though.

I too used to work in polymer extrusion, so I still receive the odd spam email from various manufacturers.

thanks 2 users thanked CptBeaky for this useful post.
peter gotch on 29/09/2021(UTC), DaiJones on 01/10/2021(UTC)
DaiJones  
#5 Posted : 01 October 2021 09:34:48(UTC)
Rank: New forum user
DaiJones

Thanks guys ive seen the information about the consultation but i cant find anything further on it.. 

As far as the list of substances of concern we would get that confirmed from the supplier that there isnt any so on that I would say I dont need to do anything further in terms of REACH UK and dont need to notify 

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