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03 April 2025

REACH and Recovered Aggregates Position Paper

REACH and Recovered Aggregates Position Paper

I.  Introduction

a) What are Recycled Aggregates (RA)?

The EU product standard EN13242 defines “recycled aggregates” as “aggregates resulting from the processing of inorganic material previously used in construction”. Besides recycled aggregates, EN 13242 defines “natural aggregates” and “manufactured aggregates”. Recovered aggregates is not defined. The definition however does not cope with the broader interpretation in some Member States with national End-of-Waste criteria. For instance, the Irish End-of-Waste regulation for recycled aggregates allows such materials as waste from concrete production, thermal processes such as ceramic production and soil and stones as input. The Dutch regulation defines the allowed input as “stoney waste”. In all cases the essence is that aggregates are produced according to a European product standard for aggregates.  All aggregates produced under these standards have in common that they fulfil a technical function, for which shape, surface and design determine fitness for use to a greater degree than chemical composition. They are all articles in the sense of REACH.

This document looks more closely into the issue of recycled aggregates produced from construction and demolition waste (furthermore: RA). These are the most abundant “secondary aggregates” and under the greatest scrutiny.

b) The crucial role of RA in sustainable construction and the circular economy

Since the REACH regulation came into effect in 2007, the EU27 has produced over 3.9 billion tonnes of recycled aggregates. This significant output has played a crucial role in advancing the circular economy, demonstrating the industry's long-standing commitment to sustainable resource management. The Sankey below shows the aggregate flow in the EU. Functional recycling of secondary materials is on a low level of about 10 %. In contrast, 15 % of the CDW is still landfilled.

Read the position paper here