Notice to suppliers re. polymeric substances
Please note the following chemicals are not considered polymers under REACH, as outlined in “no-Longer polymers (NLP) List Version 3” (2007) and should not be described as ‘EXEMPT’ or ‘POLYMER’ on the HOCNF. The ruling comes under the 7th Amendment of “European Inventory of Existing Commercial Chemical Substances (EINECs), and therefore all listed or ‘new’ polymers should be notified under the EINECS and REACH registration schemes.
While the list is not exhaustive, many ‘new’ polymers under current registrations encompass the types of chemical on the ‘no longer polymer list’ but are still being referred to as “polymers” and “exempt”.
A polymer should have a molecular weight of >10,000 and a molecular weight distribution. Under the 7th Amendment the polymer should also be characterised “by the sequence of one of more types of monomer units and comprising a simple weight majority of molecules containing at least three monomer units which are covalently bound to at least one other monomer unit or reactant and consists of less than a simple weight majority of molecules of the SAME molecular weight” (Directive 92/32/EEC, Article 2, 1c).
The NLP list consists of the following groups:- alkoxylated substances, oligomeric reaction products, oligomers from one monomer only, dimers and trimers and ‘polymer-like substances containing 50% or more by weight of species of the same molecular weight.
Examples of these include:-
- Alkoxylated substances (e.g.:- ethoxylates, propoxylated and butoxylated with a range of average alkoxylation).
- Oligomeric reaction products (better described as UVCBs for example 4,4’-Isopropylidenediphenol, oligomeric reaction products with 1-chloro-2,3-epoxypropane, reaction products with cyclohex-1,2-ylenediamine. These can also contain structural units with ‘polymer like characteristics’ and usually has the prefix ‘poly’.
- Oligomers from one monomer only (e.g. homopolymers – styrene, oligomers)
- Dimers and Trimers (e.g. ‘Fatty Acids, C18-unsaturat., dimers’ or ‘Fatty acids, C18-unsaturated dimers reaction products with…’
- Polymer-like substances containing 50% or more by weight of species with the same molecular weight:- contain 50% or more by weight of species with the same molecular weight which use the “poly” prefix (e.g. Poly(oxy-1,2-ethanediyl), .alpha.-butyl-.omega.-hydroxy; * Propene, homopolymer, reaction products with maleic anhydride, monomethyl ester, lanthanum salts and Formaldehyde, polymer with aniline, reaction products with maleic anhydride
- Substances with an alkyl range (e.g. Alcohols C12-15, ethoxylated; alcohols, C12-15-branced, ethoxylated, alcohols, C12-15-branched and linear, ethoxylated) because while the alkyl derivative is present the degree to which it is present is unknown as a result ‘READ-ACROSS’ from broader alkyl ranges do not cover narrower, or individual ones. Also included in this group are “Fatty acids, tall-oil, oligomeric reaction products with… etc…(NOTE:- fatty acids with an alkyl range without other specification represent straight chain fatty acids only). This also covers mixtures of oligomers generally with the name of the main component in the mixture at >80% e.g. fatty acids C18-unstd., with 80% dimers, 15% trimers and 5% higher oligomers are also no longer polymers.”