People and the environment are widely exposed to polymers, the main constituents of plastics, as these chemicals continue to build up in terrestrial and ocean ecosystems and production is predicted to continue increasing (Geyer et al., 2017), resulting in emissions to our waterways of up to 53 million metric tons (Mt) per year by 2030 (Borrelle et al., 2020). Apart from plastics, polymeric substances are present in many other materials, products and applications, including but not limited to silicones, coatings, paints, detergents, household and personal care products, agricultural fertilizers and wastewater treatment, often leading to direct releases into the environment.
Although polymers are manufactured and used in Europe in extremely high quantities (e.g. plastic production in Europe has been around 60 million tonnes per year over the last years (PlasticsEurope, 2020)), not enough is known about their identity, uses, physical, chemical, and hazardous properties, particularly because polymers have so far been exempt from registration under the European chemicals regulations REACH. To finally initiate the polymer registration process, currently the European Commission (EC) is developing a proposal on how and which polymers to register (Wood and PFA-Brussels, 2020).
As scientists working in the fields of polymer chemistry, ecotoxicology, environmental chemistry, conservation biology, environmental sciences, marine biology, atmospheric pollution, food packaging and sustainability assessment, we would like to provide our expert opinion on the proposed process and criteria for identification of polymers requiring registration (PRR) under REACH, as reflected in the discussion documents from the Competent Authorities for REACH and CLP (CARACAL) subgroup on polymers (CASG-polymers), including the modified PRR flowchart proposal referred to as “New Figure 3.2” in the EC’s “BACKGROUND DOCUMENT for the CASG-polymers meeting 16 Dec 2020 14:00-17:30” (see https://circabc.europa.eu/ui/group/a0b483a2-4c05-4058-addf-2a4de71b9a98/library/6381dbc9-2e88-4034-a86d-f5fd20f9ac70/details, accessed 11.04.2021) and the EC’s document “An initial thought starter on REACH information requirements for Unique Polymers Requiring Registration” (see https://circabc.europa.eu/ui/group/a0b483a2-4c05-4058-addf-2a4de71b9a98/library/2f699825-5e4a-4d0c-87e6-a015c4da3645/details, accessed 11.04.2021).
IPCP, 30 April 2021