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New Guidance for Monomers and Polymers Under REACH
July 2007 (07B-131)

With the entry into force of REACH regulation on June 1, 2007, the newly established European Chemicals Agency (ECHA) published a new guidance for monomers and polymers.

This Guidance provides definitions of monomers and polymers, and describes tasks/obligations regarding the manufacture/import of monomers and polymers. It also briefly accounts for analytical methods which may be used by manufacturer or importer of polymeric substances to establish their obligation under REACH. To view a copy of the complete Guidance document, visit:  http://reach.jrc.it/03_rdds_web_content/polymers_en/polymers_en.pdf

Registration Obligation for Polymers
A polymer itself is exempted from registration under REACH. However, the manufacturer or importer of a polymer must submit a registration to the ECHA for the monomer substance(s) or any other substance(s), that has not already been registered by an actor up the supply chain, if both the following conditions are met:
 
(a) the polymer consists of 2% weight by weight (w/w) or more of such monomer substance(s) or other    substances(s) in the form of monomeric units and chemically bound substances(s);

(b) the total quantity of such monomer substance(s) or other substance(s), i.e., the quantity of these substances ending up in the final polymer substance as unbound or chemically bound to the polymer, makes up 1 ton or more per year.

In addition, unbound additives (except stabilizers) in the polymer are also required to be registered if manufactured or imported in such a polymer preparation in quantities of at least 1 ton per year.

How About Articles Made of Polymers?
Polymers in articles are also exempted from registration. Nevertheless, the producer or importer of an article containing a polymeric substance has otherwise the same obligations under REACH as for any other standard substance present in the article.

How Bureau Veritas Can Assist You
Bureau Veritas is a leader in consumer products testing services. With experienced technical professionals, we can assist companies in compliance with various requirements under the REACH regulation. Furthermore, we offer comprehensive services to address specific product and supply chain concerns including:
 Analytical Testing
 Auditing
 Inspections

For more information: Please contact your client service representative or visit: www.cps.bureauveritas.com/reach for more information about REACH and our services.  For information in Chinese visit: http://cps.bureauveritas.cn/html/56137.html


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Bureau Veritas Consumer Products Services, Inc. (“BVCPS”) provides the information in this client bulletin as a resource of general information.  It does not replace any applicable legal or regulatory requirements and is provided “as is.”  BVCPS will not be liable for any indirect, special, punitive, consequential or other damages (including without limitation lost profits) of any kind in connection with this client bulletin.  BVCPS DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, EXPRESS OR IMPLIED, INCLUDING WITHOUT LIMITATION WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE, IN CONNECTION WITH THIS CLIENT BULLETIN.

Copyright © 2007 Bureau Veritas Consumer Products Services, Inc.  All Rights Reserved. 

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