The proposals to require REACH registration or “notification” of polymers should take into account reactive flame retardants. As part of the new EU Chemicals Strategy for Sustainability, the European Commission is proposing to require REACH registration of polymers “of concern” and possibly “The obligation to NOTIFY … ALL polymers … from the threshold of 1 tpa.” (DG ENV – ECHA 1 April 2022).
Recent Commission proposals 30th March 2022) no longer include the obligation of registration for polymers containing > 0.2% w/w lithium, boron, phosphorus, titanium, manganese, iron, nickel, copper, zinc, tin or zirconium, which would have directly impacted some polymeric PIN flame retardants (Wood 2020 proposals).
pinfa underlines however that the proposed requirement of “notification” of “all” polymers needs to be clarified concerning reactive flame retardants and other plastics additives. It would be unworkable for the industry value chain if, every time an FR reacts with a polymer during compounding or textile finishing, the result is considered to be a “new polymer” requiring a “new notification”, which would have to be made by the compounder or the textile processor.
The European Commission proposals for polymer REACH registration are based on the Wood report, June 2020, doc. ref. 40867-WOOD-XX-XX-RP-OP-0002_S3_P03.5
Development of the Commission’s proposals can be followed on the publicly accessible CIRCABC website of the Commission’s CARACAL group (Competent Authorities for REACH and CLP), sub-group CASG-06 Polymers https://circabc.europa.eu/ui/group/a0b483a2-4c05-4058-addf-2a4de71b9a98/library/806e87e4-1236-4b2b-a768-de1ac2ba15c4