Polymers Requiring Registration (PRR)

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 Technical Task Force (Polymers TTF) 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 published a paper supporting the polyesters exemption in the context of the registration of polymers. When defining polymers subject to registration, polymers without relevant toxicological or ecotoxicological properties will be considered as polymers of low concern (PLC) and exempt from registration obligations. The PLC concept would in principle apply to polyester polymers manufactured from predefined monomers under the so-called ’Polyester Exemption‘. The Polyester Exemption already exists in other jurisdictions such as the United States, Canada and Australia.

FEICA welcomes the European Commission’s proposal to keep an exemption for polyester polymers made from monomers on the EU list when polymers subject to registration requirements are defined. While FEICA considers the polyester exemption to be scientifically supported, we acknowledge that the list of starting monomers should be updated to eliminate hazardous monomers. This publication includes the FEICA proposal for a list as a starting point for the Commission and the European Chemicals Agency (ECHA) to develop an EU list of authorised monomers.

FEICA leaflet on Notification of Polymers

In support of our Position Paper, FEICA developed a concise leaflet, available in 7 languages:

 

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.

During the sixth CARACAL Subgroup polymers meeting held on the 15 December 2021, the planned impact assessment for the registration of polymers to be commissioned by the European Commission was discussed. FEICA submitted to CIRCABC a paper on the impact of the proposed changes to the molecular weight criteria for the polymers of low concern (PLC) definition and the impact of an exemption for polymeric precursors linked to strictly controlled conditions. This paper covers FEICA comments after sixth CASG polymers meeting.

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. In addition, FEICA published a presentation with 4 practical examples, demonstrating that polymeric precursors can be safely handled under adequately controlled conditions without causing harm to humans or the environment. The examples cover:

  • One-Component Foam (OCF) - Industrial + Professional
  • Direct Glazing (windshield bonding for cars) – Industrial + Professional
  • Lamination of flexible substrates with reactive polyurethane (PU) adhesives – Industrial
  • Liquid 2-component silicones for gasketing – Industrial

This presentation can be viewed here.

The European Commission proposed an exemption for polymeric precursors but only if they are handled as intermediates and strictly controlled conditions (SCC) are warranted along the supply chain. With this publication, FEICA would like to bring to the attention of the stakeholders why SCC cannot be applied to polymeric precursors used by downstream users.

FEICA participated in the 7th CARACAL Subgroup polymers meeting held on 23 February 2022. With this paper, FEICA submits follow-up comments about the notification, grouping and naming of polymers.

FEICA joined the 8th CASG polymers meeting held on 2 May 2022

The meeting was the last of a series of meetings where the upcoming registration of polymers has been discussed by the European Commission, ECHA, Members state representatives and other stakeholders. During the 8th meeting, the PRR criteria, the grouping, the notification and information requirements for polymers. The FEICA polymers task force has been an active contributor to the CARACAL subgroup, materials shared are available at: https://www.feica.eu/our-projects/reach/polymers-requiring-registration

The slides to the FEICA webinar on the upcoming registration of polymers are available via the FEICA information center.

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