Polymers: EU Working on REACH Registration Draft

The EU Commission would like to develop a proposal for the registration of selected polymers by 2022. According to Chemical Watch, the Commission announced its plans to participants in the CARACAL meeting at the beginning of November 2019. So far, neither registration nor evaluation of polymers has been required by REACH.

Requirements for registration are planned to be introduced step by step. An industry consultation sponsored by the EU is currently studying which polymers are to be prioritized. A closing report on the study’s results is expected in 2020 or 2021.

Considering the ever-growing presence of microplastics, the urgency of limiting the introduction of plastics into the environment is increasing every day. The ECHA Risk Assessment Committee experienced the hotly debated nature of the issue at its meeting in September. The ECHA received about 500 comments on the agency’s proposed limitations.

Above all, NGOs are demanding quick action. They have added a list of demands to the letter they sent to the EU at the beginning of November 2019. Among other items, they call for “swift and comprehensive” registration of about 20,000 chemicals, including nanomaterials and polymers, that are manufactured or imported in small quantities.

Article 138, Paragraph 2 of REACH is the foundation for mandatory registration of polymers. According to that section, the EU is advised to create legislative proposals when polymers pose a danger to the environment and human health. It must present a report on:
A. The risks posed by polymers in comparison with other substances.
B. The need, if any, to register certain types of polymer, taking account of competitiveness and innovation on the one hand and the protection of human health and the environment on the other.

In the past, meeting the requirements of point B have proven difficult.

But the EU is hardly a forerunner in the registration of polymers. Registration is already required in the following countries:

South Korea
The new K-REACH regulation has been in effect since the start of 2019. It has increased the number of chemicals to be registered and now includes all existing chemicals manufactured in or imported into South Korea in a quantity greater than one ton per year. Polymers with high molecular rates that were previously thought to be safe must now be registered unless an exception regulation applies. K-REACH follows the specifications of the Organisation for Economic Co-operation (OECD) for the definition of a polymer.

In August of this year, the Japanese Ministry of Health, Labor, and Welfare (MHLW) published a positive list of synthetic resins that may be used in food contact materials. The list categorizes chemicals by polymer, monomer, and additive. The list of vase polymers (plastics) contains 67 kinds of such categories.

In the United States, polymers are regulated by the Toxic Substances Control Act (TSCA). Manufacturers and importers must send a premanufacture notice (PMN) to the U. S. Environmental Protection Agency (EPA) within 90 days of the start of production. Only under certain circumstances, such as when the number of oligomers lies below a specific percentage, they are exempted from this obligation.

Polymers manufactured in or imported into China that are not listed on the Inventory of Existing Chemical Substances (IECSC) are considered new chemical substances. That means that Chinese companies must register these polymers with the Chemical Registration Centre (CRC).

If you have any questions about plastics or the safety of your products, please contact us at reach@kft.de.

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