Defining a System for the Notification of Polymers

A system for the notification of polymers should be defined in the event of a change in their treatment under REACH.

At present, polymers do not have to be registered under Regulation (EC) No. 1907/2006 of the European Parliament and the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). Nevertheless, a possible change in the treatment of polymers is envisioned in Article 138(2) of REACH, which may result in polymers being included in the registration requirements.

In addition to the registration of polymers, another important issue that of their notification. The European Commission may ask industry to give notification regarding information concerning certain polymers. Should this happen, notification would apply not just to polymers that need to be registered but also, quite likely, to all polymers in the marketplace. Currently, REACH requires information only for substances that are registered. A system for the notification of polymers should therefore be defined.

Notification Considerations

A system for the notification of polymers should be reasonable, safe, and efficient and should be about the control of data. According to the Wood-PFA project, authorized by the commission to determine which polymers should be registered, about 200,000 polymers are on the market in Europe. Notification of polymers, then, could become a formidable task: For every one of these 200,000 polymers, one legal entity or more than one such entity would require notification. Control of data, therefore, is critical.

As regards notification of polymers, then, data first needs to be concise. This means that data must be confined to a data set comprising the following:

The identification of the manufacturer or importer
The CAS number if it is available
The name of the chemical
The tonnage band

There might be requirements for additional data, but this data should not be included in the notification data set. The European Chemicals Agency (ECHA), moreover, should consider the specified data set as confidential business information not to be made available to the public.

In addition to being concise, the generation of data should not be required. Analytical or test data, for instance, ought not to be included in notification. If there is a request for notification data, too much unanalyzed, raw data will be submitted to ECHA. In order for data collection to be justified, data submitted in notification would have to be processed and analyzed, an enterprise that would tax the resources of ECHA considerably. Furthermore, data generated for notification including polymers not needing to be registered (e.g., polymers of low concern (PLCs) and polymeric precursors), might subsequently go unused.

In other words, data submitted in notification should be useful, as data generation per se does not help protect human health and the environment, and might put an administrative burden on polymer manufacturers and ECHA. The goal is to have a balance between human health and the well-being of the environment on the one hand, and business innovation and growth on the other.

More information on Polymers Requiring Registration (PRR) is available via www.feica.eu. FEICA’s positions regarding the registration and notification of polymers is available in a leaflet, published in seven languages, that is available via www.feica.eu/information-center/latest-news/notification-of-polymers.