IDENTIFYING GAPS IN REACH REGULATION FOR RECYCLED TIRE PRODUCTS AND INITIAL PROPOSED

"Purpose of the article The aim of this paper is to identify and critically assess gaps in the current REACH Regulation related to polycyclic aromatic hydrocarbons (PAHs) in products made from recycled tires and to propose initial, risk-based solutions. Methodology/methods The paper is based on a qualitative analysis of relevant REACH regulatory provisions combined with a review of recent scientific literature on PAH content, migration and bioaccessibility in recycled tire products. The paper focuses on three main aspects: the dominance of PAH content testing over migration and bioaccessibility-based assessments, the lack of harmonised testing methods across EU member states, and the reliance on outdated toxicological data and exposure assumptions. Although the current regulatory framework aims to ensure a high level of consumer protection, its strong emphasis on total PAH content does not adequately reflect real world exposure conditions. Recent scientific studies examining PAH migration and bioaccessibility from recycled tire rubber and crumb rubber infill demonstrate that actual human exposure levels are often substantially lower than those implied by total content values alone. Scientific aim Building on this evidence, the paper proposes several initial regulatory adjustments to improve the scientific consistency and proportionality of PAH regulation under REACH, including the introduction of harmonised EU wide migration testing protocols that better reflect realistic exposure scenarios, a systematic re evaluation of PAH limit values based on up to date scientific findings, and a more explicit consideration of socio economic impacts for the tire recycling industry. Findings Findings indicate that, in some applications, existing regulatory limits may be overly conservative and not fully aligned with a risk-based approach to chemical safety. Conclusions The proposed measures aim to support a more balanced regulatory framework that maintains a high level of consumer protection while enabling circular economy objectives and supporting the sustainable growth of recycling markets for end of life tiress.