In the fourth meeting of the EU Competent Authorities for REACH and CLP (CARACAL) subgroup on polymers held online on June 22, 2021, the grouping of polymers requiring registration under REACH (FPF reported) and their joint submission was discussed in detail.
Currently estimated at 200,000, the number of polymers on the EU market is considered very high. Grouping them is therefore intended to help manage polymers in a cost-effective way that limits the burden on industry and reduces animal testing while providing a higher level of protection for human and environmental health. During the fourth meeting of the CARACAL subgroup on polymers, EU member states, industry representatives, and NGOs agreed that it is crucial to define clear group boundaries, e.g., to avoid group splitting after registration, and to consider animal welfare throughout the entire process. However, there was disagreement between stakeholders on the group size, which defines the number of polymers in one group. Questions discussed in this regard included: Which degree of hazard heterogeneity within a group is acceptable? What are the options to consider the different molecular weights of one polymer in grouping and registration since hazard properties are assumed to change with the molecular weight?
A generic challenge in polymer registration under REACH is that hazard data is missing for most polymers. This is also one of the reasons why ECHA has proposed to use “similar chemical composition as the main grouping principle,” which would “have the [further] benefit of consistency with existing REACH criteria.”
Other agenda points discussed during the meeting without yet reaching a consensus included the EC’s proposal for an EU definition of polymers of low concern as well as the EC’s proposed flowchart to identify polymers requiring registration. As part of each meeting, ECHA also reported the current status and lessons learned from pilots in which ECHA works together with five industry sector groups. The objective is to verify the technical grouping principles, elaborate on different grouping principles, and evaluate existing groups’ hazards.
By the end of 2021, the CARACAL subgroup on polymers is mandated to advise the European Commission in its development of a proposal for polymer registration under REACH. Given the lack of consensus in the discussions so far, debates are expected to continue.
According to an article published by the European Environmental Bureau (EBB) on June 21, 2021, the meetings of the CARACAL subgroup on polymers are dominated by industry groups, that “have taken the floor 63 times, 75% of the time.” Earlier this year, the International Panel on Chemical Pollution (IPCP), a group of independent academic scientists, published a joint statement in which they found the EC’s proposal on the registration of polymers under REACH too narrow. The group argued that it would not properly reflect all potential impacts that the great variety of polymers can have on human and environmental health (FPF reported).
European Commission (June 08, 2021). “Thought starter on substance identification and joint submission obligations of Polymers Requiring Registration” REACH information requirements for Unique Polymers Requiring Registration.”
European Commission (June 08, 2021). “Proposal for an EU-Definition of a Polymer of Low Concern (PLC).”
European Commission (June 08 2021). “PRR-Identification flowchart.”
ECHA (June 11, 2021). “ECHA report to CASG on the Cefic Sector Groups pilots on grouping of polymers.”
European Environmental Bureau (June 21, 2021). “First laws to tackle serious polymer health threat being crippled.”
Almroth, B. et al. (April 30, 2021). “Statement on the Registration of Polymers under REACH and List of Signatures in Support.” International Panel on Chemical Pollution
The Guardian (June 21, 2021). “New EU rules would permit use of most polymers without checks, experts warn.”