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.
FEICA recently published a Position Paper with the perspective of the adhesives and sealants industry on the registration of polymers. Polymers are currently exempted from registration under Regulation (EC) No. 1907/2006 of the European Parliament and of the Council on REACH Regulation. 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.
FEICA has asked the Commission to consider the particularities of the adhesive and sealant industry. Criteria to define polymers requiring registration should be clear, scientifically sound and globally harmonised. Exemptions and reduced registration requirements, in applicable cases, should be considered by the legislator. See FEICA’s comments on the Wood/PFA report regarding PRR.
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 market requirements and how big the number of affected polymers could be, check here.