On November 26, 2020, Chemical Watch reported on a meeting of the EU competent authorities for REACH and CLP (CARACAL) where the possibility for installing a mandatory pre-registration requirement for all polymers under REACH was discussed.

This pre-registration step would include an obligation for companies to provide a minimum set of data on all polymers imported to or manufactured in the EU. The collected data would help to evaluate whether a polymer requires full registration under REACH or not.

During the meeting, EU member states, industry representatives, and NGOs debated the necessity and feasibility of such a pre-registration process. Many EU member states welcome this idea, as it would provide more accessible data for the identification of potential hazardous polymer groups. In contrast, without additional data collected through pre-registration, many high tonnage polymers may not be evaluated at all as they currently fall under the category “polymers of low concern.”

However, industry representatives voiced concern that pre-registration could overstretch the limited resources of the European Chemical Agency (ECHA). NGOs responded that all other chemicals were also pre-registered, and the cost of such a phase would be comparatively small. Both the European Commission (EC) and ECHA itself withheld from the discussion. Tatiana Santos from the European Environmental Bureau (EEB) argued the cost problem could be solved by implementing a fee-based approach that could also act as a “filter on polymer production.”

The discussion is to be continued in the next meeting scheduled in 2021.

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FEICA (January 18, 2021). “Registration of Polymers – Adhesives and Sealants Industry Perspective

Chemical Watch (November 26, 2020). “Pre-registration of polymers draws support from EU member states.