Discussion on the impact of REACH to the polymer industry featured at April OHEIC meeting... Dr. Herbert Estreicher of Keller and Heckman LLP presented Occupational Health and Environmental Issues Committee (OHEIC) members with 'The Effect of REACH on Polymer Materials,' an overview for manufacturers, importers and downstream users of substances affected by the European Union's (EU's) Registration, Evaluation and Authorization of Chemicals (REACH) regulation.
While an EU regulation, the impact is global as supply chains will need to communicate on substance uses, safety data and other information to ensure the continued availability and approval for use of affected substances.
The presentation addressed the elements of REACH, data sharing, use of an 'Only Representative' by non-EU entities for substance registrations, registration information and data requirements, current requirements for polymers and monomers, possible future registration of polymers, biopolymers, residual monomers and residual solvents and stabilizers.
Criteria have been established for the registration of monomers manufactured or imported in the EU. Polymers are not currently subject to registration but may be subject to restriction and authorization. Future legislation could be proposed to require registration of polymers.
Areas where the polymer industry can become more engaged were noted, including:
Reviewing polymer data (i.e., case histories on notified polymers and other sources) and determining whether the data establish a risk, and
Developing a strong case on the impact of registration on competitiveness and innovation.
A Q&A on REACH is available and guidance is being developed through various REACH Implementation Projects (RIPs).
More information...
Marie Martinko at (202) 974-5330
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