ESPP submitted comments to EU REACH REFIT consultation

ESPP has submitted input to the EU’s public consultation on the REFIT (assessment of fitness for purpose) of the EU Chemical Regulation 1907/2006 (“REACH”). ESPP considers the Regulation as having improved information about chemicals used in Europe, so contributing to public confidence and safety. ESPP’s specific comments noted that the exemption of digestate from REACH should be confirmed; underlined the importance for the nutrient circular economy of Art. 2(7)d which specifies that sites producing “recovered substances” (e.g. struvite recovered from wastewaters) do not have to register under REACH (subject to certain conditions) but noted that clarification is needed to ensure fair sharing of costs and administration for this disposition; and noted that adaptation of REACH should be considered to facilitate registration of recovered nutrient products covered by the EU Fertilisers Regulation (after revision is completed), subject to ensuring safety. REACH is complex to apply to variable or organic substances, such as many recycled nutrient products, and partly inappropriate because it is intended to address the substance, and not impurities, which will be specified in the Fertilisers Regulation.