END-OF-WASTE

TURNING WASTE
INTO VALUABLE RESOURCES

The utilisation of waste derived materials is quite often subject of debate regarding the actual status of “waste”. In various countries, even within the EU, various views existing on the status of a waste derived material, especially when it is used in combustion processes. Different views exist when materials are used in recycling applications. At N+P we believe in a transparent approach to all subject related to legal matters and therefore we have dedicated this page to give transparency on our approach to the subject of end of waste.

End-of-Waste under REACH

From the 1st of January 2026, N+P have self-declared their Subcoal® as end-of-waste under REACH. Following extensive work together with renowned Dutch consultancy firm Royal Haskoning, the conclusion was made that Subcoal® will be classed as an end-of-waste material when used in specific applications. Although official legal statements on this topic are rarely given by the Dutch authorities, all documents, reports and analyses backing our self-declaration have been shared with the relevant authorities. For that reason the development of N+P’s Subcoal® has led to a bespoke material which is designed specifically for usage, dosage and reaction.

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Based on all conditions, requirements, and criteria for End-of-Waste status as laid down in Article 6 of the Waste Framework Directive (WFD) and the Guidance on waste or non-waste of the Dutch Ministry of Infrastructure and Water Management (IenW), the following is established:

  • Production and use: Subcoal® is produced from waste materials, has undergone a recovery operation, and is directly applied as an auxiliary material in industrial applications.
  • Specific and certain application: There is a specific market for the application of the Subcoal® product as an alternative material to fossil materials, which shows a demonstrable (market) demand.
  • Technical and legal requirements: Subcoal® complies with all relevant product legislation (REACH, POP Regulation) and international standards (ISO TC 300 for SRM). Within the framework of REACH (1907/2006/EC), Subcoal® is classified as an article, and therefore no registration or information obligations apply.
  • Environment and health: The recovery use of Subcoal® as an auxiliary material in industrial applications  has no adverse effects on the environment or public health and leads to CO₂ reduction and the replacement of fossil carbon sources.

The final conclusion is that Subcoal® from N+P, when applied as an auxiliary material in industrial applications , has achieved End-of-Waste status.

This means in concrete terms:

  • Subcoal® does not need to be treated, registered, and/or notified as waste for its specific application.
  • REACH registration and information obligations do not apply; however, a Safety Data Sheet (SDS) for Subcoal® from N+P is available for customers, carrier(s), and competent authorities.
  • The Waste Shipment Regulation (WSR/EVOA) no longer applies to the cross-border transport of Subcoal®.