EchA says unreacted monomers in polymers may need registration

ERJ staff report (DS)

Helsinki, Finland - The European Chemicals Agency (ECHA) has published an update to the Guidance for monomers and polymers following the conclusion of the consultation process. The guidance covers the possible need for registration of unreacted monomers within bulk polymers.

Polymer molecules are generally regarded as representing a low concern due to their high molecular weight, this group of substances is exempted from registration and evaluation under REACH. However, ECha now says that manufacturers need to be aware that unreacted monomers within the polymer material may be subject to EChA rules.

The ECHA Guidance for monomers and polymers was first published in 2008. A need for an update arose following the European Court of Justice Judgement C-558/07. It clarified that the concept of monomer substances refers to both reacted and unreacted monomers (REACH Article 6(1) and 6(3)). This potentially has a direct impact on the registration obligations as previously outlined in the Guidance.

Relevant concepts have been clarified in specific sections of the document. In particular, additional reference to REACH Article 6(1) to cover the registration obligations for unreacted monomers and other substances in a polymer has been made. The Guidance has also been aligned with the newly agreed interpretation on natural polymers already outlined in ECHA's Frequently Asked Questions on REACH. Other minor changes and editorial corrections have also been made.

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Press release from EchA - contains links to useful resources

New guidance document (April 2012) on Monomers and Polymers from EchA