30,000 polymers may become subject to REACH registration

Registration of polymers is currently exempt from the REACH regulation. Instead, importers and manufacturers of polymers must register the constituent monomers when certain criteria are met. The European Commission, however, has a public consultation seeking feedback from stakeholders on the proposal to require the registration of polymers of concern.

REACH registration has already cost industry an estimated €3bn and registration of polymers would add another €2.5bn to the bill.

Registration of polymers of concern

A 2020 study estimated that there are 200,000 polymers on the EU market and up to 30,000 may require registration. The researchers created criteria for polymers requiring registration (PRR):

• Cationic polymers;
• Anionic polymers;
• Amphoteric polymers;
• Non-ionic polymers with surface-active properties;
• Low molecular weight polymers;
• Polymers containing low molecular weight oligomers;
• Polymers with reactive functional groups; and
• Some types of degradable polymers.

It is unclear if these same criteria will be used in legislation to confirm in-scope polymers. It is also assumed that the process for registration will not change but there may be adaptations to the information requirements.

Health and environmental benefits

Polymers are currently exempt from REACH registration and evaluation. Removing these exemptions would provide ECHA with a much larger dataset for polymers on the market. This will greatly improve evaluation and identify polymers of concern. Once identified as a Substance of Very High Concern (SVHC), these polymers may be subject to further regulatory measures such as authorisation or restriction.

The registration of polymers of concern would contribute to health and environmental benefits of around £30bn over 40 years, according to researchers.

Chemicals Strategy for Sustainability

Polymers have been exempt from registration since REACH was first legislated. There are several reasons for this including the view that polymers were generally safe.

Owing to the potentially extensive number of different polymer substances on the market, and
since polymer molecules are generally regarded as representing a low concern due to their
high molecular weight, this group of substances is exempted from registration and evaluation
under REACH. Polymers may however still be subject to authorisation and restriction.

Guidance for monomers and polymers, Version 2.0, April 2012 – European Chemicals Agency

The Chemicals Strategy for Sustainability (CSS) stated that the commission will “make a proposal to extend the duty of registration under REACH to certain polymers of concern”. This is a response to the fact that the EU is lacking “a comprehensive information base on all substances placed on the market”.

What is next for registration of polymers?

Companies that import or manufacture polymers should keep abreast of these developments. Legislators will apply effort confirming in-scope polymers and consider by when they must be registered. Industry and other stakeholders will have opportunities to comments during the process.

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