REACH Registration for Polymers: What the EU Plans

It is a given that mandatory registration for polymers will come. The legal framework for it, including notification and registration deadlines, will be defined in the proposed revision of REACH, which should be published by the end of this year. However, the exact information that registrants will need for the registration will appear in an annex that will be published later. This information was presented by the policy officer of the Environment Directorate, Katrin Schütte, at the Chemical Watch conference, “EU Regulatory Updates,” held April 19–20 in Brussels.

The entry into force of the revised REACH and the obligation of polymer registration is not expected before 2027. The definition of the term “polymer” is now being finalized. So far, Article 3 of REACH defines the term only vaguely. Schütte stated that work is now being done on determining the characteristic properties of a polymer. The work will be completed before the draft appears at the end of the year.

Plans include the classification of polymers according to atomic mass units (dalton units: Da):

  • Type 1: Polymers <1,000 Da: Registration period of 8 years
  • Type 2: Polymers 1,000–10,000 Da: Registration period of 12 years
  • Type 3: Polymers > 10.000 Da: Registration period of 12 years

All polymers manufactured or imported in a quantity greater than one per year are subject to registration.

Because of the large number of polymers – estimates speak of 200,000 on the EU market – the EU Commission expects registration to occur by groups to limit the work involved.

Notification First

In any case, companies are required to provide notification of the polymers they intend to register. Notification for new polymers that come on the market after the Regulation comes into force must occur immediately. Notification for polymers already on the market enjoy a three-year transition period.

The content and scope of the information required here have not yet been finalized. The required data will include the substance identity (CAS number), chemical composition, and structural information.

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