Let us be straight: REACH is not our core business. We are a commodity brokerage, not a regulatory consultancy. But REACH decides whether some of what we broker can legally be placed on the EU market, and the question gets asked far too late far too often. Three points cover most situations: waste is outside REACH until end-of-waste; Annex V exempts a list that includes vegetable and animal fats and oils, many fatty acids and glycerol; and pyrolysis oil, as a UVCB, generally is not exempt.
The three things that decide it
That last point is the one that surprises people. A pyrolysis project can solve chlorine, solve certification, find a cracker, and then discover that the importer has a registration obligation nobody budgeted for. It is far cheaper to ask in month one.
- Waste is not a substance under REACH. Material that is legally waste falls outside the registration obligation. The moment it reaches end-of-waste and becomes a product, REACH applies. So the same material can be outside REACH in one jurisdiction and inside it in the next, for exactly the same reason it can be a waste in one and a product in the other. See pyrolysis oil on the waste-or-product question.
- Annex V exempts a lot of what we broker. The exemption list includes vegetable fats, oils and waxes, animal fats, oils and waxes, a range of fatty acids and their common salts, and glycerol. That covers a great deal of the vegetable oil, animal fat and glycerine trade.
- Pyrolysis oil usually is not exempt. It is a UVCB, a substance of unknown or variable composition, and once it is a product rather than a waste, placing it on the EU market at or above one tonne a year generally brings a registration obligation on the manufacturer or importer.
Where it comes up in practice
- Importing pyrolysis oil into the EU. The importer carries the obligation, and volume thresholds are per legal entity per year.
- End-of-waste transitions. The day your material stops being waste is the day REACH starts applying to it.
- Additives and process chemicals, which are straightforwardly in scope with their own classification, labelling and safety data sheet requirements. See additives and blending.
- Downstream user obligations, where you are using a registered substance outside the conditions the registrant assessed.
- Research and development, where PPORD notification can give a time limited exemption for product and process orientated research. Relevant to pyrolysis and chemical recycling projects that are still developing a specification rather than selling one.
What we do and do not do
We do not register substances, we do not write dossiers and we do not give regulatory or legal advice. What we do is raise the question at the point where it is still cheap to answer, tell you what we understand the position to be and where we are uncertain, and put you in touch with people who do this properly.
Everything on this page is orientation. REACH obligations depend on your role, your tonnage and the specific substance, and the consequences of getting it wrong land on you rather than on us. Verify with a REACH specialist or with ECHA before you rely on any of it.
Frequently asked questions
Does REACH apply to waste?
No. Material that is legally waste is outside the REACH registration obligation. Once it reaches end-of-waste status and becomes a product, REACH applies. This is why the waste-or-product question matters twice: once for shipment rules and once for chemical compliance.
Does pyrolysis oil need REACH registration?
Generally yes, once it is a product rather than a waste. Pyrolysis oil is a UVCB, a substance of unknown or variable composition, and placing it on the EU market at or above one tonne per year normally brings a registration obligation on the manufacturer or importer. It is not covered by the Annex V exemptions that cover many fats and oils. Confirm your specific position with a REACH specialist.
Is used cooking oil exempt from REACH?
While it is waste, it is outside REACH entirely. Beyond that, the Annex V exemption list covers vegetable and animal fats, oils and waxes, many fatty acids and glycerol, which covers a large part of this trade. The exact position depends on the material and your role, so check rather than assume.
Is glycerine exempt from REACH registration?
Glycerol appears in the Annex V exemption list, which is why crude and refined glycerine generally move without a registration obligation. As always the exemption applies to the substance as described, so confirm your specific material and role.
What is PPORD?
Product and process orientated research and development. A notification route that can give a time limited exemption from registration while you are still developing a substance or process rather than placing it on the market commercially. It comes up regularly with pyrolysis and chemical recycling projects that are still working towards a stable specification.
Do you handle REACH registration for us?
No, and we would be the wrong people to try. We are a commodity brokerage. What we do is raise the question early, tell you what we understand and where we are not sure, and introduce you to people who do this professionally.
Who to ask about REACH & product compliance
Ask us. Unsure whether your material needs registering? Ask before the cargo moves, not after it arrives. We answer the same working day, in English or Dutch, and there is no charge and no obligation for a market read or a second opinion on a specification.
You get Bart van den Brug directly, not a call centre and not a form that goes nowhere. We are an independent broker: we never take title, we do not trade our own book, and we are paid a commission only on business that actually concludes. That is why we will also tell you when the answer is no.
+31 6 115 83 448
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Sustainable Commodities 3 B.V., Lemmer, the Netherlands
Last reviewed 09 August 2026 by Bart van den Brug, Sustainable Commodities 3 B.V. (KvK 99665042), Lemmer, the Netherlands. Regulatory references are given for orientation and are not legal advice; verify against the current Official Journal text before contracting.