The life cycle and supply chain of a substance ends with the waste stage. ‘Waste’ means any material which the holder discards or intends or is required to discard. The recovery process focuses on the recovery of the substance from that waste. Where waste materials cease to be waste, a new life cycle of the substances starts. Recovery is therefore considered equal to manufacture under the REACH Regulation.

The Waste Framework Directive (2008/98/EC) defines recycling and recovery as follows:

• ‘recycling’ means any recovery operation by which waste materials are reprocessed into products, materials or substances whether for the original or other purposes. It includes the reprocessing of organic material but does not include energy recovery and the reprocessing into materials that are to be used as fuels or for backfilling operations
• ‘recovery’ means any operation the principal result of which is waste serving a useful purpose by replacing other materials which would otherwise have been used to fulfil a particular function, or waste being prepared to fulfil that function, in the plant or in the wider economy.

The main difference between recycling and recovery thus is the final product, which is either a “product, material or substance” or a “waste serving a useful purpose”. However, under the REACH Regulation, this distinction is not made. REACH only speaks of ‘recovered substances’. REACH (and CLP) obligations hence apply to both recycled and recovered substances in the same way as to any other material (with a number of exceptions granted conditionally).

Update: in order to support the improvement of waste separation and recycling techniques and prevent contamination of recovered and recycled substances, information on Substances of Very High Concern contained in articles is made publicly available in the SCIP database. Within one month following its launch at the end of October 2020, the SCIP database has already received over 50,000 notifications. As of January 5^th, notification of information on articles containing SVHCs in a concentration above 0.1% (w/w) is compulsory.