PAULA DIAZ RODRIGUEZ
FEICA – Association of the European Adhesive & Sealant Industry, Brussels, Belgium

Abstract

By the end of 2022, the European Commission will publish a proposal to amend the REACH Regulation. This amendment, among other things, will extend registration requirements to polymers, currently exempted. Among the different actors, downstream users will be considerably impacted by this paradigm change.

In any consideration of key regulatory updates today in Europe, the forthcoming revision of the European Union’s REACH Regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals) (1) is significant. As a consequence of this revision, registration requirements will be extended to polymers. This revision of REACH should give careful consideration to potential effects on downstream users. I will cover three aspects of the revision of REACH: recent background history regarding requirements for the registration of polymers with a consideration of the difference between non-polymeric substances and polymers, and the legal implication of this difference; the situation of downstream users with respect to registration of polymers, especially regarding customisation needs; and the balancing of customisation, important as it is, with the safeguarding of human health and the environment.

As far as the recent background history regarding requirements for the registration of polymers is concerned, it is first necessary to distinguish between non-polymeric substances and polymers and to consider the legal implication of this distinction. Non-polym ...