REA releases a clarification note on REACH, CLP and COMAH regulations

REA has released a NOTE regarding the application of REACH, CLP and COMAH regulations to digestates. 

Defra and HSE have seen the note and confirmed that our interpretation is correct in terms of REACH and CLP. However, with regard to COMAH regulations our interpretation is not straightforward as the HSE cannot currently provide a definitive answer on whether COMAH applies to digestates or not. The HSE continues to work on this issue and is interacting with some of the other European Member States and DEFRA to clarify this issue. They are also planning to have a face to face meeting with REA and other interested parties in the coming months. REA will continue to liaise with the HSE to clarify this matter and will keep its members updated on progress. 

Work may need to be done in the future to identify whether digestate has hazardous properties that trigger its classification under COMAH as an aquatic pollutant with acute or chronic toxicity effects (if a site is storing more than the 'qualifying quantity'). However, before undertaking this kind of work, we would suggest waiting for further updates on the HSE's discussions with European Member States and DEFRA and further clarification on whether this work is really necessary . 

Last update: 03/09/2014

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