FEICA Highlights Importance of Reasonable Approach to Extension of Polymer Registration Requirements
Several relevant parameters need to be considered regarding a proposed registration of polymers under REACH, according to FEICA.
In a recent position paper entitled “Registration of Polymers–Adhesives and Sealants Industry Perspective,” FEICA, the Association of the European Adhesive & Sealant Industry, explains the perspective of the adhesives and sealants industry regarding the registration of polymers. Polymers are currently not included in the registration requirements under Regulation (EU) No. 1907/2006 – Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH). However, in terms of Article 138(2) of REACH, a possible further review is foreseen to extend the registration requirements to polymers.
If the risk posed by certain polymers can be proven, and practical and cost-efficient ways of selecting polymers requiring registration (PRR) can be established, registration requirements under REACH will be extended to polymers. Several relevant parameters need to be considered regarding a proposed registration of polymers. As so many polymers are used in the adhesives and sealants industry (possibly 500-1,500 for an individual manufacturer, if no grouping of polymers is considered), registration would be very difficult for medium-sized and small businesses. (Annex 1 of FEICA’s position paper provides detailed examples of the multiplicity of polymers.)