The potential for registering polymers was originally built into the European Reach Regulation under Article 138(2). Due to the diversity and large number of polymers on the European market, they were exempted from registration under Reach although the monomers themselves would need to be registered. Alternatively, companies manufacturing polymers would need to buy the monomers from a Reach-registered source. Later, concerns were raised over polymers which might have more inherent hazards than others, and whether they might invite further regulation.
The European Commission is developing a proposal, which is targeted for delivery in 2022. To this end, CARACAL has set up a sub-group on polymers (CASG-Polymers), where their mandate was decided at the CARACAL meeting in July.
The Burden of Proof is moving in the way that regulators need to prove why any polymer should be on “Polymers Requiring Registration (PRR) and not Polymers of Low Concern (PLC). However, the criteria have not been defined yet, and that will be key.
CASG-Polymers will have 15 observers, who have already been nominated. When its work is done, the CASG-Polymers will be disbanded at the end of December 2021. Key in their work will be the conceptual framework for polymer rick assessment, prepared by ECETOC, on the link below
Linmark Consulting has specific experience in polymer regulation and is in a good position to assist clients in this area. Further information will be posted on this site, as the issue develops.

European Union revises polymer regulation under Reach