Polymers are currently exempted from registration under REACH. However, Article 138(2) foresees a possible further review to extend the registration requirements to polymers. If the risk posed by certain polymers can be proven, and practical and cost-efficient ways of selecting polymers requiring registration (PRR) can be established, registration requirements under REACH will be extended to polymers.
To comply with that mandate, the European Commission is working to identify polymers requiring registration, proposing grouping criteria, defining the registration process and assessing the costs/benefits of polymers registration.
A specific task force on Polymers Requiring Registration has been created in 2020 within ISOPA. Its objective is to ensure that the specific chemistry of diisocyanates is being considered when defining those polymers which would require registration.
The main message being conveyed to the decision-makers is that the majority of our polymers can be identified as polymeric precursors, which are well controlled in the industrial environment and should therefore be excluded from the registration requirements.