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.
- 1Substance identified
- 2Role established: manufacturer, importer or trader
- 3Registration by the party that owes it
- 4Safety data sheet from the supplier
- 5Downstream use communicated
A broker is not a supplier within the meaning of Article 3(32), so it cannot issue a safety data sheet. Only the actual supplier can.
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.
Where do you actually apply, and what does it cost
The question everyone asks second, after they discover REACH applies to them. The answer is more concrete than the regulation makes it sound.
Registration goes to ECHA, the European Chemicals Agency, through their REACH-IT portal. The dossier itself is built in IUCLID format, and IUCLID has a Validation Assistant that pre-checks for missing information before you submit, which is worth running before you pay anything.
| 1. Inquiry | Submit an inquiry through REACH-IT to find out whether the substance is already registered and who else is registering it. |
|---|---|
| 2. Join or lead | If it is already registered you join the existing joint submission, which is far cheaper and faster. If not, someone has to be lead registrant and build the dossier. |
| 3. Data | Collect the safety, environmental and exposure information the tonnage band requires. More tonnage means more data. |
| 4. Dossier | Build it in IUCLID, run the Validation Assistant, submit through REACH-IT. |
| Tonnage bands | 1 to 10, 10 to 100, 100 to 1,000 and over 1,000 tonnes per year. The band drives both the data requirement and the fee. |
| Fees | Roughly EUR 1,558 for a joint submission in the 1 to 10 tonne band, up to about EUR 40,270 for an individual submission above 1,000 tonnes. Joint is dramatically cheaper than going alone. |
| Timeline | Commonly 3 to 6 months from first inquiry to a valid registration number if you are joining an existing submission. Considerably longer as a lead registrant building a new dossier. |
| Non-EU producers | You cannot register from outside the EU. You appoint an EU-based Only Representative under Article 8, and they carry the obligation. This catches out almost every first-time exporter into the EU. |
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.
Where do I apply for REACH registration?
To ECHA, the European Chemicals Agency, through their REACH-IT portal. The dossier is built in IUCLID format, and IUCLID's Validation Assistant will pre-check it for missing information before you submit. Start with an inquiry through REACH-IT to find out whether the substance is already registered, because joining an existing joint submission is dramatically cheaper than leading a new one.
What does REACH registration cost?
The ECHA fee runs from roughly EUR 1,558 for a joint submission in the 1 to 10 tonne band up to about EUR 40,270 for an individual submission above 1,000 tonnes per year, under the fee regulation in force since 5 November 2025. SME reductions apply. Consultancy and testing costs come on top and are usually the larger number. Confirm the current fee before budgeting.
How long does REACH registration take?
Commonly 3 to 6 months from first inquiry to a valid registration number if you are joining an existing joint submission. Considerably longer if you are the lead registrant building a new dossier, because then the data generation sits on your timeline.
I produce outside the EU. How does REACH work for me?
You cannot register from outside the EU. You appoint an EU-based Only Representative under Article 8 who takes on the registration obligation on your behalf, and your EU importers are then covered. This is the single most common surprise for first-time exporters into Europe, and it is far cheaper to arrange before the first cargo than after it.
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.
Market news
Recent headlines from across the feedstock and renewable fuel sector. Nothing specific to this market has come through the wires lately, so this is the wider view. The links go to the publisher; we do not host or edit their reporting, and a headline here is not our endorsement of it. Scroll for more.
- Kimchi waste could become viable feedstock for bioplastics
- Braskem biobased polymer helps Deterra drug disposal pouch earn packaging awards
- Eni and PETRONAS to explore high-performance bio-gasoline
- Linglong signs $2 billion Egypt investment MoU
- BTMA to represent European national associations at Tyres Europe board meetings
- Osaka Gas claims STS LNG bunkering first in Osaka Bay
- ISWG-GHG 22: Non-profits react
- USTC brings Copenhagen-based offices together in new hub
- ORLEN instigates new Baltic regional energy initiative
- TotalEnergies Lubmarine launches lubricant for 4-stroke medium speed marine engines
- IMO carbon price heads for December showdown
- LyondellBasell: Pyrolysis Reactors Installed for MoReTec Plant in Wesseling
- Sustainable aviation fuel pioneer completes successful trials
- Louis Dreyfus Company to generate biogas from citrus waste
- Nature by Design: A decade of IUCN, Monaco collaboration driving circular solutions for biodiversity
- European Digital Sustainability Skills Conference
- UCL reacts to IMO ISWG-GHG: ‘Steady progress on the Net Zero Framework’ made but ‘high uncertainty’ remains
- ISWG-GHG 22: ‘Genuine willingness’ for further NZF progress, observes Chair
18 headlines, updated automatically. Last refreshed .
Sources and further reading
Primary sources for the rules and figures on this page, so you can check them yourself. Legislation is amended: always read the consolidated text on the date that matters to you.
Who to ask about REACH & product compliance
Just ask. Unsure whether your material needs registering? Ask before the cargo moves, not after it arrives. You get Bart van den Brug on the other end, same working day, in English or Dutch, and across the team also in French, Portuguese, Polish, Czech and Russian.
On how we work: on the feedstocks and fuels on this site we are a broker. We never take title, we do not trade our own book, and we are paid a commission on business that concludes. Additives are the one exception: those we also buy and sell for our own account, and we say in which capacity we are acting before you commit to anything. Either way you will hear it from us when the answer is no, or when your parcel is not ready for the conversation you want to have. A market read or a second opinion on a specification costs nothing and commits you to nothing.
Happy to look at whatever you have, even if it is half an analysis and a question.
+31 6 115 83 448
bart@sustainablecommodities.eu
Sustainable Commodities 3 B.V., Lemmer, the Netherlands
Ask about REACH & product compliance
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Or e-mail us directly: bart@sustainablecommodities.eu
Last reviewed 08 September 2026. Regulatory references are given for orientation and are not legal advice: verify against the current Official Journal text before contracting.