read

As a first step, notification will be required for all EU manufactured or imported polymers above 1 tonne per year – both PRR and non-PRR. This step intends to map the vast polymer universe. Limited information on the polymer will be required for their notification – more information for PRR and less information for non-PRR. The overview of polymers on the EU market shall allow the definition of grouping criteria. Grouping of the polymers will be crucial to handle the extensive registration needs of PRR. A grouped registration of several similar polymers relies on the assumption of hazard homogeneity with a common set of information obtained from one or more test substances.

In a second step, registration of PRR will be required. The information requirements for the registration will depend on the molecular weight (MW) for the polymers. There will be an assignment to three different types of polymers:

Type 1: low MW polymers
Type 2: medium MW polymers
Type 3: high MW polymers

While Type 1 polymers are expected to have the same information requirements as non-polymeric substances, the information requirements for Type 2 and Type 3 polymers will be very limited. Also under discussion is an exemption from the registration requirement for polymeric precursors, i.e. polymers used to produce other polymers or articles.

The revised REACH proposal, to be presented by the end of the year, will contain the basic provisions for polymers. The exact details of the registration of PRR, such as the information requirements, are unlikely to be part of this proposal. They will be amended as part of the new annex a few years later.