Recyclers have to comply with REACH
It seems that recycled materials may need to be 'pre-registered' under the EU REACH regime, although the guidance on this is not clear.  
See Section: Recycled or recovered substance already registered  
In ECHA Guidance on registration  
Link: ... 
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Guidance on registration (REACH)
Posted: 11/05/2008 By: Professor Paul Bardos