Under the REACH Regulation, substance recycling (and recovery) is considered equal to manufacture. In the same way as for other substances subject to REACH registration, the substance identity must be established.

The information considered to be sufficient for correct identification and naming of the substance is listed in Annex VI, and includes:

• Name(s) in the IUPAC nomenclature or other international chemical name(s)
• Other names (usual name, trade name, abbreviation)
• EINECS or ELINCs number
• CAS name and CAS number
• Molecular and structural formula
• Information on optical activity and typical ratio of (stereo) isomers
• Molecular weight or molecular weight range
• Degree of purity
• Nature of impurities, including isomers and by-products
• Nature and order of magnitude (… ppm, … %) of any additives (e.g. stabilising agents or inhibitors)
• Analytical data (including normally spectral and chromatographic data) of the substance.

Obtaining analytical data for recycled substances is not always straightforward. For example, the waste stream from which the substances are recovered may be highly variable, or the recycled product is a (complex) mixture rather than an individual substance. Where this is the case, the recycling operator must document information that is specifically relevant to the recovered substance, such as:

• Origin of waste
• Control of input material
• Spectral data (if available)
• Description of process steps that ensure that certain impurities are not present

It must be clearly stated and argued why this data is sufficient to justify the identity of the recovered substance(s). Using this information, “substance sameness” can be determined, based on which the recycling operator can examine whether the recycled substance is exempted from REACH registration.