Smithers Rapra issues REACH polymer alert

Smithers Rapra believe many companies are still confused or may even be receiving incorrect information on the REACH requirements for polymers. It is important to ensure that monomers chemically bound in polymers are appropriately pre-registered by 1 December 2008. Assuming that your product is exempt from pre-registration is not an option worth considering. To help you with decisions, Steffen Erler, Director of REACH Services advises to follow the check-list below: * Chemically bound monomers and other reactants bound in polymers must be pre-registered. The 2% rule refers to the quantity of bound monomeric units and other bound reactants. * The current view of regulators is that any company in the European Economic Area that is producing a polymer or chemically modifying a polymer must pre-register the monomers and other bound reactants, even if these have already been pre-registered by an actor further up the supply chain. * The monomers of naturally occurring polymers can be considered as non-isolated intermediates. * Recyclers of polymers in the European Economic Area must pre-register the monomers bound in the polymers that they recycle, as well as other substances. * Polymeric substances with over 50% of species with the same molecular weight are unlikely to be considered as polymers under REACH. * It is more appropriate to consider some polymer-like substances as complex reaction products or substances of unknown or variable composition. * Many polymers are preparations/mixtures under REACH: solvents and additives must be appropriately pre-registered. * The first registration deadline is only 2 years away; this includes many highly reactive monomers above 1 tonne. * Chemical Safety Assessments of monomers and other reactants must sufficiently account for risks arising as a result of the use of the monomers and reactants during production, as well as relevant use and disposal of the polymer. The application of the above points depends on relative tonnages and other scoping criteria for pre-registration.