The non-governmental organizations European Environmental Bureau (EEB) and ChemSec have submitted a position statement to the Competent Authorities for REACH and CLP (Caracal) subgroup that was convened to discuss the potential process for polymer registration under REACH. The two organizations are calling for the generation of micro- and nanoplastics to “be regarded as an inherent hazardous property of plastic polymers” and for a pre-registration process for polymers under REACH to require registrants to submit data that enables an estimation of a polymer’s generation of micro/nanoplastics over its life cycle based on its physico-chemical properties and impacts experienced during manufacture, use, and end of life.

Some stakeholders have advocated for exempting polymers considered to be of low concern. However, the statement argues that “since most polymers can be reasonably expected to generate microplastics, a minimal set of data allowing to estimate the resulting microplastics emissions and associated risks should be submitted for all synthetic polymers produced or imported in the EU.” Further, it specifically recommends requiring registration under REACH for polymers produced in extremely high volumes and for polymers “having high propensity to generate large quantities of secondary microplastics, or to generate microplastics associated with a specific hazard.”

The statement on micro/nano plastics was submitted following a first meeting of the responsible Caracal subgroup on September 11, 2020. The discussions have primarily been centered around reviewing proposals included in a July 2020 report for the development of criteria to identify and group polymers for registration under REACH (FPF reported). The NGOs also submitted a set of comments on this report to the Caracal subgroup before its first meeting, suggesting several modifications to the proposed criteria and calling for a mandatory pre-registration process where a set of defined minimal data should be submitted for all polymers produced or imported into the EU.

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EEB and ChemSec (October 2, 2020). “NGO position: REACH Requirements for polymer registration under REACH should include consideration of polymers’ contribution to micro- and nanoplastics burden in the environment.”

EEB and ChemSec (September 11, 2020). “ChemSec and European Environmental Bureau comments to wood and PFA report on polymer registration.”

Andrew Turley (October 8, 2020). “Include microplastics in REACH polymers criteria, NGOs say.” Chemical Watch

Andrew Turley (October 15, 2020). “Cefic aims to finalise polymer grouping projects ‘by end of 2021’.” Chemical Watch

ChemSec (November 10, 2020). “How can we trust that plastic is fantastic if producers keep the ingredients secret?