Polymers are the main building block of plastics and some have very high production volumes along with a high exposure potential. Still, they have so far been exempted from registration under the EU’s chemicals regulation, REACH, due to the assumption that “high” molecular weight polymers are not systematically taken up by organisms and thus, cause no biological effects. However, recent scientific evidence demonstrates otherwise.
In an article published on December 13, 2022, in the journal Environmental Science Processes & Impacts, Ksenia J. Groh from the Eawag, Swiss Federal Institute of Aquatic Science and Technology, Dübendorf, Switzerland, and co-authors evaluated the polymer assessment and management approaches currently used in different jurisdictions worldwide. Based on identified gaps, options to modernize polymer management in the EU and beyond were provided. In this regard, the authors hope that their analysis is useful in developing a strong mechanism for polymer registration under REACH. As part of the REACH revision (FPF reported and here), the European Commission (EC) is currently working on a proposal for polymer registration under REACH (FPF reported and here) whose finalization was postponed from the end of 2021 to 2022 (FPF reported), and in October 2022 was again postponed by a year.
Reviewing global regulatory approaches to polymers, Groh and co-authors found that most were developed in the early 1990s or before. The EC’s latest draft criteria to identify polymers requiring registration under REACH (April 2022 as of this writing), would also be rooted in regulatory approaches from the early 1990s. However, the authors highlighted that in the last 30 years the scientific knowledge on environmental fate and effects of polymers has advanced significantly. For instance, polymers with a molecular weight >1000 Da have been observed in aquatic organisms demonstrating the possibility of their uptake potentially due to “molecule folding.” Furthermore, chronic exposure to polymers was found to result in non-systemic toxicity and in inflammatory reactions even at low levels (FPF reported).
Overall, the authors emphasized that data on the environmental hazards are missing, such as effects of degradation and weathering, a differentiation between chemical hazards (whole chemical mixtures contained/released by a polymer), and hazards due to the polymer’s physical properties (e.g., size).
To improve polymer registration in the EU (under REACH) and other parts of the world, the researchers assert four points they believe policymakers need to consider:
- An increased transparency around polymers’ chemical identities and physical characteristics.
- A better “understanding of environmental fate of polymers with regard to transitions across size categories and exposure profiles.”
- A better understanding of polymers’ environmental hazards, also considering effects of degradation, weathering, “long-term toxicity, physical-mechanic effects and geophysical impacts,” to be supported by the “development of standard protocols and testing procedures.”
- To require a different amount of data in dependence on the production volume as well as the use and release profile of the respective polymer: “The greater the production volume and/or the likelihood of environmental releases, the greater the data requirements should be over the entire lifecycle of a polymer.”
To generate and collect all the necessary data on polymers, the scientists highlighted the need for manufacturers and policymakers to work together, to make the data publicly accessible, and to develop new polymer identifiers (FPF reported). Groh and co-authors also provided requirements for polymers to meet circular economy demands. For instance, to allow products made of polymers to be readily reusable and recyclable, chemical and material simplification would be necessary and “must be driven standardization of material compositions and properties.”
Reference
Groh, K. J. et al. (2022). “Assessing and managing environmental hazards of polymers: historical development, science advances and policy options.” Environmental Monitoring and Assessment. DOI: 10.1039/d2em00386d
