The future regulation of new polymers and recycled polymers: a challenge for nomenclature and grouping Chris Howick INOVYN Chlorvinyls Limited, UK Chris has worked in chemicals regulation for over thirty years, involving submission of REACH dossiers and notifications for food contact polymers under various national and international schemes. He has also been involved in submission of dossiers for the authorisation of recycled polymers in the EU REACH scheme and plays a highly active role in REACH consortia and relevant committees of CEFIC, Plastics Europe, the UK Chemical Industries Association and the British Plastics Federation. Whilst the world of polymer science advances with new syntheses, marvellous innovations and insights into the understanding of polymers, it is important to remember that society, while marvelling at such developments, also requires such advances to remain sustainable and meet the ever-evolving requirements of consumer and environmental safety. Until now, polymers, although initially proposed for registration, have not been required to be registered under the European (and hence UK) REACH regulation. Instead a somewhat complex compromise was developed to ensure that some additional obligations were required of companies placing polymers on the market. However, as part of the EU's Chemicals Sustainability Strategy (EU-CSS), an intention to require companies to notify all polymers and to register some polymers to the European Chemicals Agency has been announced. This will require companies to group similar polymers together so as to minimise animal testing and, consequently, how polymers and polymer families are described in terms of their chemistry will be critical to ensuring that such a scheme reflects the realities of polymer science in the 2020s and is able to provide the safety guarantees that regulators, companies and citizens alike, are requesting. Moreover, both the EU-CSS and European Union Circular Economy Strategy (CES) give requirements for the recycling of polymers, whether post-industrial or post-consumer. The CES requires a move from linear to circular supply chains, requiring significant increases in polymer recycling volumes. The CSS, however, cautions recyclers to ensure a high knowledge of the identity and composition of polymers to be recycled. These seemingly contradictory obligations can only be solved through knowledge of polymer identity and composition, each of which may vary in each value chain. This is where chemistry - especially advanced analytical chemistry - must play a part and some recent case studies will be described. This presentation will give an overview of the current situation and the likely future developments that will need to take place for such a significant regulatory step to be successful. References 1. REGULATION (EC) No 1907/2006 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCILof 18 December 2006 2. REGULATION (EC) No 1272/2008 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 16 December 2008on classification, labelling and packaging of substances and mixtures, amending and repealing Directives 67/548/EEC and 1999/45/EC, and amending Regulation (EC) No 1907/2006 (Text with EEA relevance)(OJ L 353, 31.12.2008, p. 1) 3. The ECETOC Conceptual Framework for Polymer Risk Assessment (CF4Polymers):Technical Report No. 133-1 EUROPEAN CENTRE FOR ECOTOXICOLOGY AND TOXICOLOGY OF CHEMICALS,Brussels, May 2019 4. ISSN-2079-1526-133-1
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