Registration of Polymers: Are the Hazards of Degradation Products the Key Criterion?

For some time now, the EU has striven for mandatory registration of polymers. But which polymers are to be registered according to the requirements of REACH? And above all, which criteria should apply to the registration? Although no consensus yet exists to answer these questions, some key points have been crystallized.  

In the opinion of EU member states, polymers should be registered when they degrade into substances of concern. That’s the finding of a document with comments from various representatives of EU member states and organizations that was presented to the CARACAL group of experts and serves as a proposal for a PRR (Polymers Requiring Registration) criterion. 

For example, the German Federal Institute for Occupational Safety and Health (BAuA in its German abbreviation) finds the criterion important because it counts on the concept of safe and sustainable by design. The Institute regards the concept as a pillar of a new EU chemicals strategy for sustainability.  

Associations have criticized the proposals made so far. They see the criteria for biological degradation as too vague and the current testing methods in use unsuitable and useless for polymers. That’s why they are requesting that appropriate test methods be approved before any legal requirements for the registration of polymers go into effect. 

Environmental organizations feel that focusing only on questionable degradation products is inadequate. Microplastics, they believe, should also be regarded as a critical degradation product and taken into consideration for registration. Germany, however, rejects using the fact that a polymer can degrade into microplastic as a registration criterion. 

For more background information, such as in which countries polymers are already registered, see our blog post Polymers: EU Working on REACH Registration Draft

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