Registering polymers in Europe, the NGO perspective

Huge amounts of polymers are being produced, imported and used in Europe. The plastic converter demand for the main types of polymers raised to over 51 million tons during 2017 and this represents only part of the total demand. Polymers are the basic ingredients of a very wide range of materials and products (plastics, resins, paints etc.) to which people and the environment are widely exposed every day and will increasingly be exposed in the future as plastics and other polymeric products continue to build up in maritime and ocean ecosystems and production is predicted to continuously grow.

Despite this wide and growing exposure and rising concerns about their impact on health and the environment, there is no obligation to register polymers under REACH – and therefore provide information on their health and environmental hazards. This difference of treatment between polymers and monomers is due to an exception introduced in the original text of the REACH Regulation upon its adoption in 2007. At the time, polymers were considered to be less hazardous than monomers. Registration of polymers was also considered too complicated due to the high number of different polymer chains. The solution to the problem was simply postponed, as often in chemical regulation, by a REACH provision giving to the Commission the power to expand the registration obligations to polymers.

According to REACH (Art 138(2) the Commission may: “present legislative proposals as soon as a practicable and cost-efficient way of selecting polymers for registration on the basis of sound technical and valid scientific criteria can be established, and after publishing a report on the risks posed by polymers in comparison with other substances; and the need, if any, to register certain types of polymer, taking account of competitiveness and innovation on the one hand and the protection of human health and the environment on the other. ”

Two studies on the issue have already been developed for the Commission2. The Consultancies Wood and PFA, have been now contracted for a study on the development of criteria to identify and group Polymers Requiring Registration under REACH and their impact assessment.

This paper presents NGO’s views on the registration of polymers.