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Transforming Waste into Products

Directive 2008/98/EC

The European Union Waste Framework Directive (2008/98/EC) promotes the reduction, reuse, and recycling of materials to move towards a circular economy. This directive introduces concepts such as by-product and end-of-waste status, which are crucial for transforming waste into resources, closing the material loop, and minimizing their environmental impact.

By-product

A by-product is a substance or object resulting from a production process whose primary purpose is not the production of that substance or object. For a waste to be considered a by-product, it must meet the following conditions:

  • It is certain that the substance will be used subsequently.
  • It is used directly without having to undergo any treatment other than normal industrial practice.
  • It is produced as part of a production process.
  • All relevant requirements relating to products and the protection of human health and the environment for the specific use are met, and it does not produce adverse impacts on the environment or human health.

End-of-waste status

The end-of-waste status occurs when a waste, after being subjected to a recovery operation (including recycling), meets the following conditions and is considered a secondary raw material:

  • It must be used for specific purposes.
  • There must be a market or demand for the product.
  • It must meet technical requirements for specific purposes, existing legislation, and applicable product standards.
  • Its use does not generate adverse impacts on the environment or human health.

At ServiREACH, we can help you determine if you meet all the requirements to consider a waste as a by-product or to request the end-of-waste status. We handle the preparation of all the necessary supporting documentation to submit the authorization request to the Administration.

  • Byproduct Authorization Application We collect, evaluate, and generate the necessary documentation so that your waste can be considered a byproduct.
  • End-of-waste Status Authorization Request We gather, assess, and generate the required documentation for your waste to no longer be considered waste and obtain the secondary raw material status.
  • REACH Registration Obligations We assess whether your company is required to have a REACH registration for the new product or whether any of the existing exemptions can be claimed.
  • REACH Registration We help you prepare the registration dossier for substances that need it, ensuring your business meets the regulatory and supply chain requirements.
  • Hazard Classification We perform the hazard calculation of substances and chemical mixtures according to the classification criteria of the CLP Regulation. We enhance this service with the preparation of a justification report based on these hazard calculations, and if necessary, offer a proposal for laboratory testing to certify it.
  • Consulting With our expert advice, we can efficiently and carefully address your queries, becoming a trusted ally and providing quick solutions to any technical questions.

Frequently Asked Questions about Waste

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For a waste to be legally considered a by-product (and for you not to have to pay for its management as waste), it must meet four key conditions:

  1. Have a guaranteed safe subsequent use
  2. Be used directly without further processing (beyond normal industrial practice).
  3. Be an integral part of your production process.
  4. Comply with health and environmental protection regulations.

At ServiREACH, we assess whether your material meets these requirements and prepare all the technical documentation for the By-product Authorization Request to present it to the Competent Authority and officialize its status.

“End-of-Waste Status” occurs when a waste is processed (recycling or recovery) until it becomes a safe and useful secondary raw material legally ceasing to be “waste”. The benefit is twofold: you stop treating it as a discard (with associated costs) and obtain a new product with market value that you can sell. We help you process the Authorization Request by demonstrating that there is a market for that product and that it meets the required technical specifications.

Yes, it is very likely. By recovering a substance from waste and converting it into a new product or secondary raw material, you become a “manufacturer” under REACH. This could oblige you to register the substance. However, the REACH Regulation considers certain exemptions for recovered substances if they are already registered by others. At ServiREACH, we conduct a study of your REACH registration obligations to determine whether you should register the substance or if we can apply an exemption, saving you unnecessary costs.

The classification is not arbitrary; it depends on the chemical composition and properties of the waste. We carry out the Hazard classification applying the criteria of the CLP Regulation (Classification, Labelling and Packaging). We perform the theoretical hazard calculations and prepare a justification report. If the calculations are not conclusive, we propose the specific laboratory tests necessary to support the actual classification, which is decisive for understanding how you must manage and label that waste.

Yes. The bureaucracy to change the legal status of a waste (to by-product or end-of-waste status) is complex and technical. We take care of gathering, evaluating, and generating all the necessary documentation We prepare the complete dossier for the Competent Authorities, technically justifying that the requirements of the Waste Framework Directive are met, so that you can focus on production while we ensure the circular economy of your process.

Are you interested in applying for end-of-waste status or by-product authorization?

WE CAN HELP YOU!