Polymer Confidentiality Issues under REACH

Polymer Requirements and Confidentiality Issues under REACH... 

This chapter addresses nomenclature issues involving polymers, including generic definitions of polymers how polymers are named (generally by reactants) how other reactants such as free-radical initiators are considered and how polymers will be treated under REACH along with the confidentiality issues resulting from the need to register monomers and other reactants used to manufacture polymers. 

This chapter discusses the regulatory effect for a substance meeting the polymer definition in these jurisdictions, and a discussion of several special topics the two-percent rule, post-reactions and devolvement of pre-polymers, and nomenclature issues involving epoxy polymers derived from hisphenol-A and epichlorohydrin. We shall also discuss the curious requirement under REACH that monomers and other reactants in reacted form must he registered even though the polymers manufactured from them do not, including consideration of confidential information which may he compromised through this provision. 

Under EINECS, polymers were exempt from EINECS listing provided that they did not contain new monomers or other reactants. Under REACH, polymers meeting the EU definition of polymer are also exempt from registration, but the monomers and other reactants used to manufacture them must be registered even if the polymer is imported into the EU and these components are never present in unreacted form. This leads to complex issues involving normal business practices and confidentiality that are addressed in this chapter. 

---