Helsinki, 21 Febuary 2023 – On 29 June 2021, ECHA’s Board of Appeal (BoA) issued a decision on a compliance check case (A-001-2020) regarding registration obligations for polymer importers.
The Board of Appeal’s decision affects registration requirements for monomer and polymer importers and manufacturers.
ECHA’s Guidance on monomers and polymers has been revised to align with the BoA’s decision and includes changes to the description of registration obligations for those importing and manufacturing polymers and monomers.
The key changes relate to:
- the monomer that needs to be registered by the manufacturer or importer of a polymer;
- the calculation of registration tonnages of monomers ending up in the final polymer as a reacted substance;
- the information that registrants of monomers must include in a registration chemical safety report.
ECHA encourages all importers and manufacturers of polymers and monomers to examine the updated guidance and review their registrations to make sure they are complying with these minimum requirements.