Polymers are currently exempted from registration under Regulation (EC) No. 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). However, Article 138(2) of REACH foresees a possible further review of REACH to extend the registration requirements to polymers. If the risk posed by certain polymers can be proven, and practical and cost-efficient ways of selecting polymers requiring registration (PRR) can be established, registration requirements under REACH will be extended to polymers.
To comply with that mandate, the European Commission contracted with Wood/PFA for a study; the resulting report was published in July 2020. The study was aimed at identifying polymers requiring registration, proposing grouping criteria, defining the registration process and assessing the costs/benefits of polymers registration. See FEICA’s comments on the Wood/PFA report regarding PRR.
In addition to the study and to continue the work by also engaging all the relevant stakeholders, a 'Competent Authorities Sub-Group' for polymers was created under the umbrella of the CARACAL (CASG polymers). CARACAL stands for 'Competent Authorities for REACH and CLP'.
After considering the Wood/PFA report and the discussions held in the CASG, the Commission will draft a proposal to review the REACH regulation to add registration requirements for polymers by the end of 2022.
The use of polymers within the adhesives and sealants industry is very widespread. In general terms, polymers are the chemicals which enable adhesives and sealants to work.
For that reason, FEICA supports the efforts of the European Commission to develop a comprehensive regulatory framework for the registration of polymers under the REACH Regulation that will help to protect human health and the environment, without losing the competitiveness and innovativeness of the European industry.
The FEICA Polymer’s Task Force actively contributes to the discussion and publishes position papers on the different relevant topics.
FEICA general positions on the registration of polymers
FEICA regularly publishes position papers that illustrate the peculiarities of the adhesives and sealants industry and aim at contributing with technical data to the global discussion. The FEICA Position Paper from the perspective of the adhesives and sealants industry on the registration of polymers can be viewed here.
Customising polymers may result in a huge number of new polymers to be potentially registered. Further information is available in FEICA's Position Paper on Manufacturers of low-volume customised polymers at the end of the supply chain. For practical examples that illustrate how polymers are customised to fit market requirements and how big the number of affected polymers could be, check here.
The European Commission is working to extend registration requirements for polymers, currently exempted from registration under EU REACH. The Commission is considering requesting industry to notify of certain polymers’ information. FEICA is of the opinion that the notification of polymers should be limited to a concise dataset and analytical or test data should not be required at the notification stage.
FEICA leaflet on Notification of Polymers
In support of our Position Paper, FEICA developed a concise leaflet, available in 7 languages:
- Defining a reasonable, safe and efficient system for the notification of polymers (English, FEICA)
- Definition eines angemessenen, sicheren und effizienten Systems für die Meldung zu Polymeren (German, in cooperation with IVK and DB)
- Stabilire un sistema efficace, sicuro e ragionevole per la notifica dei polimeri (Italian, in cooperation with AVISA)
- Définir un système de notification des polymères adapté, sûr et efficace (French, in cooperation with AFICAM)
- Vaststellen van een redelijk, veilig en efficiënt systeem voor de notificatie van polymeren (Dutch, in cooperation with VLK)
- Definir um sistema razoável, seguro e eficiente para a notificação de polímeros (Portuguese, in cooperation with APCAS)
- Definir un sistema razonable, seguro y eficaz para la notificación de polímeros (Spanish, in cooperation with ASEFCA)
FEICA contributions as a member of the CARACAL subgroup on polymers
On 15 March 2021, as a preparation for the third CASG polymers meeting scheduled on 19 March 2021, the European Commission uploaded to CIRCABC (the EU's Communication and Information Resource Centre for Administrations, Businesses and Citizens) the document named ‘An initial thought starter on REACH information requirements for Unique Polymers Requiring Registration (PRR)’. After reviewing the document, and in line with the discussions held during the third CASG meeting, FEICA commented on the questions posed by the European Commission in the above-mentioned document. FEICA’s input on the questions posed in the thought starter, shared by the European Commission, can be viewed here.
FEICA has commented on the PRR-Identification flowchart - Update 8 June - and the proposal for an EU-definition of polymer of low concern (PLC) shared in CIRCABC, in advance of the CASG meeting of 22 June 2021 (Agenda item 5: CASG-Polymers/07/2021). See the FEICA comments here.
FEICA appreciates the comprehensive and pragmatic 'Thought Starter on substance identification and joint submission obligations of Polymers Requiring Registration' developed by the European Chemicals Agency (ECHA) and has contributed some comments in advance of the discussion during the CASG meeting of 22 June 2021 (Agenda item 4: CASG-Polymers/05/2021). See the FEICA comments here.
Within the context of the registration of polymers, a potential exemption for polymeric precursors is under consideration. The European Commission is proposing an exemption for polymeric precursors handled like intermediates under REACH. Given the importance for the adhesive and sealant industry, FEICA published a presentation explaining the difference between polymeric precursors and intermediates, and the benefits of a full exemption for polymeric precursors. You can view the presentation here or download it here.
The slides to the FEICA webinar on the upcoming registration of polymers are available via the FEICA information center.