Polymers are currently exempted from registration according to REACH Regulation (Article 2, paragraph 9). However, in the text of the Regulation (Article 138, paragraph 2) an update is already foreseen that would include registrations of polymers and the Commission will publish a proposal by 2022. Involved Competent Authorities and stakeholders are working on the definition of the criteria for the identification of polymers that will be subject to the registration obligation with the possibility to group them based on their physical-chemical properties and/or hazard classes and already established and agreed on several criteria for their exemption or inclusion. The process will not be easy and in the early stages of pre-registration and discussion, it is necessary to have a deep analytical knowledge of polymers produced and imported, which could take years to obtain, also due to the lack of adequate structures and knowledge. The knowledge on your own substances is the first step to be able to be among the protagonists and to address the market needs competitively. Kahlberg Consulting can assist you starting from the preliminary stages, keeping you updated on the regulatory course and helping you to choose the best strategies for the implementation of new requirements.
Thanks to our long-year experience we can assist you for the following services: