FIEC warns against the reclassification of recycled aggregates under the REACH regulation.

This decision would be incompatible with the EU’s circular economy and sustainability ambitions.

Any regulatory measure that hinders the implementation of the circular economy should be reconsidered.

Concerns about high administrative burden for economic operators

FIEC warns against the reclassification of recycled/recovered aggregates from CDW (construction and demolition waste) under the REACH regulation (Registration, Evaluation, Authorisation and restriction of Chemicals).

FIEC has been alerted by some of its members and a consortium of aggregates and waste management associations that recycled aggregates will be considered as “substances” under the REACH chemicals regulation.

The current classification as "article" exempts recycled aggregates from REACH registration. A change of classification to "substance" - as proposed by the European Chemicals Agency (ECHA) and CARACAL - would primarily affect those recycled aggregates for which end-of-waste (EoW) criteria have already been established. EoW criteria play an important role in increasing the acceptance and value of recycled aggregates.

Producers and other economic operators in countries where EoW criteria have been introduced would be treated unequally. If a reclassification of recycled aggregates were to require registration under REACH, the associated administrative burden for producers and contractors would be immense.

Furthermore, ECHA's decision is highly questionable in terms of its compatibility with the EU's circular economy and sustainability ambitions (European Green Deal, Circular Economy Action Plan and subsequent new EU legislation to promote circular construction): Recycled aggregates represent the largest volume of recycled materials in Europe. They are used safely and soundly in many construction works, such as road construction, bridge foundations, pavements and bank protection.

Recycled aggregates have many advantages

Recycled aggregates represent a major opportunity to recover thousands of tons of inert waste that is stored in specialised facilities or, in the worst cases, illegally dumped. Recycled aggregates are cost-effective, environmentally friendly and versatile.

Circularity is a priority for FIEC, which stresses that any regulatory measure that hinders the implementation of the circular economy in the EU should be reconsidered.

FIEC is critical of the reclassification of recycled aggregates for the reasons outlined above and calls on the EU institutions to reconsider their position and ensure that recycled aggregates remain exempt from registration under REACH.