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Q Are there registration obligations for manufacturers and importers of natural polymers that have been chemically modified?

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 meet 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. This includes natural polymers, which are chemically modified (e.g. post-treatment of natural polymers).

Monomer substance(s) or other substance(s) in the form of monomeric units and chemically bound substance(s) originating from the natural polymer can for practical reasons be treated as "non-isolated intermediates" and do not have to be registered. The substances used to chemically modify the natural polymer and which are chemically bound within the final polymer need to be registered according to the REACH requirements.

This FAQ has been agreed by the Competent Authorities of the Member States (REACH CA) in October 2008.

Modified Date: 18/05/2017
Topic: REACH
Scope: Polymers and monomers
ID: 0071
Version: 1.1
This answer has been agreed with national helpdesks.

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