On April 30, 2021, the International Panel on Chemical Pollution (IPCP) published a joint statement from scientists responding to the European Commission’s (EC) latest proposal on requirements for polymers requiring registration under the EU REACH regulation (FPF reported). Signatories of the IPCP statement hail from a variety of scientific disciplines investigating the effects of polymers on human and environmental health and consider the EC’s proposal too narrow to properly account for the variety of ways in which polymers could affect the human body and the environment.

According to the signatories, following the polymer registration criteria currently proposed by the EC, “only ca. 6% of the estimated 200’000 polymers on the EU market might require registration, while most of the polymers used in highest quantities and contributing majorly to the current plastic crisis… would not require any registration process at all.” Plastics that may not require registration under the current proposal include polyethylene (PE), polystyrene (PS), and polyethylene terephthalate (PET) all of which have documented leaching of contaminants (FPF reported). The scientists instead suggest the EC prioritizes registration of polymers produced in the highest volumes and “thus likely to result in the highest exposures.”

The EC’s draft criteria for identification of polymers requiring registration suggest prioritizing polymers that can become substances of concern when degraded. The statement signatories agree with this criterion but add that the definition of substances of concern should be much wider than those currently identified within REACH. The proposed criteria also do not account for degradation into micro- and nano-plastics even though they persist in the environment and are possibly hazardous (FPF reported).

Other considerations the signatories would like the EC to account for in polymer registration include, for example: (i) non-intentionally added substances that can be present in polymers, (ii) hazardous effects that can occur without bodily uptake such as chemicals that can cause skin rashes, (iii) other polymers that can be of concern due to the body’s inability to expel them due to their physico-chemical properties, and (iv) implementation of a notification system for all polymers marketed in the EU in order to increase transparency and allow all stakeholders to “improve the efficiency and societal value of the overall procedure for registration of polymers.”

As of this writing, signatures from scientists wishing to support this joint statement continue to be accepted. More information about how to sign the statement is available on the IPCP’s statement page.


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

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European Commission (March 15, 2021). “An initial thought starter on REACH information requirements for Unique Polymers Requiring Registration.”

European Commission (March 18, 2021). “Proposal for an EU-Definition of a Polymer of Lower Concern (PLC).”