The EU REACH regulation is expected to be revised shortly to include polymers. While polymers are currently exempt from REACH registration, monomers, oligomers, and polymers within complex mixtures (UVCBs) already require registration.
At present, some 80,000 unique substances are registered under REACH, with ECHA having evaluated just 21% of them. With the addition of some 200,000 to 400,000 polymers under REACH, the regulatory burden will increase significantly.
It is likely that polymers will be processed by ECHA in the same Reach multi-year, tiered approach, based on hazard and volume. Polymers regarded as low-hazard may be exempt from full registration, while those presenting potential risks could be subjected to further regulatory obligations. Polymer grouping is likely to require the formation of dedicated REACH consortia, to enable data sharing and compliance with EU competition laws. In addition, industry will need to adapt current test methods (EU, UN, OECD) and develop new ones tailored to the complexity and diversity of polymers; including predictive models.
Companies are well advised to start now in understanding and characterising their polymer portfolio. Early tasks would be to define if their polymers are “low concern”, or if they may require registration and how they might be grouped into clusters.
Linmark Consulting is well positioned to help companies in registration strategy, data gathering and sharing as well as later registration.