EU Competent Authorities for REACH and CLP (CARACAL) subgroup members debate on the identification of polymers requiring registration and their grouping; consider different opinions of stakeholders on group size, acceptable hazard variation within a group and options to deal with the variety of molecular weights one polymer can have; discussions to continue until end of 2021.
In the fourth meeting of the EU Competent Authorities for REACH and CLP (CARACAL) subgroup on polymers held online on June 22, 2021, the grouping of polymers requiring registration under REACH (FPF reported) and their joint submission was discussed in detail.
Currently estimated at 200,000, the number of polymers on the EU market is considered very high. Grouping them is therefore intended to help manage polymers in a cost-effective way that limits the burden on industry and reduces animal testing while providing a higher level of protection for human and environmental health. During the fourth meeting of the CARACAL subgroup on polymers, EU member states, industry representatives, and NGOs agreed that it is crucial to define clear group boundaries, e.g., to avoid group splitting after registration, and to consider animal welfare throughout the entire process. However, there was disagreement between stakeholders on the group size, which defines the number of polymers in one group. Questions discussed in this regard included: Which degree of hazard heterogeneity within a group is acceptable? What are the options to consider the different molecular weights of one polymer in grouping and registration since hazard properties are assumed to change with the molecular weight?
A generic challenge in polymer registration under REACH is that hazard data is missing for most polymers. This is also one of the reasons why ECHA has proposed to use “similar chemical composition as the main grouping principle,” which would “have the [further] benefit of consistency with existing REACH criteria.”
Other agenda points discussed during the meeting without yet reaching a consensus included the EC’s proposal for an EU definition of polymers of low concern as well as the EC’s proposed flowchart to identify polymers requiring registration. As part of each meeting, ECHA also reported the current status and lessons learned from pilots in which ECHA works together with five industry sector groups. The objective is to verify the technical grouping principles, elaborate on different grouping principles, and evaluate existing groups’ hazards.
By the end of 2021, the CARACAL subgroup on polymers is mandated to advise the European Commission in its development of a proposal for polymer registration under REACH. Given the lack of consensus in the discussions so far, debates are expected to continue.
Food Packaging Forum, 23 June 2021