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Q Are there registration obligations for manufacturers and importers of natural polymers that have not been chemically modified?3
Natural polymers are understood as polymers which are the result of a polymerisation process that has taken place in nature, independently of the extraction process with which they have been extracted (i.e. they may or may not fulfil the criteria set out in Article 3(39) of the REACH Regulation).
Following Article 2(9) of the REACH Regulation, any polymer meeting the criteria of Article 3(5) of the REACH Regulation does not have to be registered.
According to Article 6(3) of the REACH Regulation any manufacturer or importer of a polymer shall submit a registration for the monomer substance(s) or any other substance(s) that meet the criteria mentioned in the respective article. However, monomer substance(s) or other substance(s) in the form of monomeric units and chemically bound substance(s) in natural polymers can, for practical reasons, be treated as "non-isolated intermediates" and do not have to be registered.
3This FAQ has been agreed by the Competent Authorities of the Member States (REACH CA) in October 2008.
Modified Date: 04/06/2015
Topic: REACH
Scope: Polymers and monomers
ID: 0070
Version: 1.0
This answer has been agreed with national helpdesks.

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