NIWO certificate

 

The Niwo certificate means that YF International has a business license to be active in recycling
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Reach


Regulation EC 1907/2006 affects all parties engaged in producing and selling chemicals products and products or preparation made thereof in the EU. Because of the pro-active character of Reach all players have to establish their respective position and take the appropriate actions. From the start of Reach YF International has followed this course and is therefore able to confirm its Reach compliance.

YF International’s business is in recycling synthetic polymers in the form of (mainly technical) fibres or engineering plastics. Under Reach these products qualify as polymers (see definition Reach art art. 3.5) and articles (see definition Reach art 3.3).
There is a clear distinction between products re-used for e.g. extrusion which polymeric substances under Reach and filaments or fibres (chopped or milled) which are classified as articles.
Polymers are exempt from Reach provided that the monomers are registrated (Reach art. 6.3).
Reach does not apply to articles unless in the case of intended release of substances from the article (notification ; Reach art 7.1) or in the case of presence of substances of “very high concern” – SVHC (Reach art. 7.2).
The polymeric materials that YF International trades in do not have a “intended release” function and do not contain any SVHC substances.

Therefore YF International’s Reach position is the following :
- No registration requirements for the products because they are polymers or articles
- No notification requirements because of no intended release from and no SVHC present in articles
- Registration requirements of the monomers corresponding to the respective polymers
Reach art. 6.3 states that monomer registration is needed only if the monomers have not already been registered by actors up the supply chain. In the case of recycling polymeric materials these registration will have been made by the producers (or importers) of the virgin material.
Nonetheless YF has obtained pre-registrations for all monomers of the polymers that are part of YF International’s portfolio.
Reach also requires the MSDS to be updated according to the Reach requirements. Although the products are not classified as hazardous materials and therefore no Safety Data Sheet is formally required , YF International will provide an up-to-date Product Information Sheet for each product.
 

Reach position


YF International is fully aware of the obligations that come with the “Reach Regulation” EC#1907/2006 on the Registration, Evaluation, Authorisation and Restriction of Chemicals.
 
As far as YF International business activities are affected by Reach, YF International is in compliance with the Regulation and will comply with this Regulation in the future if so required.
 
As the business of YF International is in the re-use of polymeric substances and polymeric materials its business is not directly affected by Reach (Application; art. 2.9)
 
However: in the case of polymeric substances art 6.3 applies (General obligation to register substances on their own or in preparations) , meaning that a registration of the monomer substances must be obtained, unless it has already been registered up the supply chain. This provision affects YF International in the way that if in the supply chain (from original producer up to YF International’s position in this chain ) the original monomer registration cannot be linked to YF International , an own monomer registration must be obtained.
And in the case of polymeric materials art. 7 applies (Registration and notification of substances in articles). This provision affects YF International in the sense that any (unintended) release or presence of substance of very high concern is to be notified.
 
In case of polymeric substances YF has already obtained monomer registrations or is in the process of doing so.
This is summarized in the table below :
 
Product name

Substance name 

(monomer; art. 6.3)

Registration List of Uses and Exposure Scenarios
PA 6
(Nylon 6)
ε-Caprolactam Co-Registration Available via
Caprolactam Reach Consortium
PA 6.6
(Nylon 6.6)
Adipic acid  Co-Registration Available via
Adipic Reach Consortium
PA 6.6
(Nylon 6.6)
Hexamethylene-diamine (HMDA) Co-Registration  Available via
Adipic Reach Consortium

 

In the case of polymeric materials (e.g. fibers for re-use purposes) YF International has verified the possible occurrence of substance in the materials against the SVHC candidate list for authorization.
No suspect substances are to be found in YF International products, YF International being Reach compliant in this respect.

Although Reach doesn’t apply to polymeric substances and therefore no downstream information of the safety in use and handling of the substance according to Reach is required and although the polymeric materials are not classified as dangerous substances under the relevant laws, it is YF International’s opinion that in the spirit of Reach such information should be available to her customers.
Based on the Reach format YF International has prepared “Product Information Sheets” for the products in her portfolio which are available upon request.