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REACH: do you really know the composition of your polymers?

Polymers are ubiquitous in many industrial sectors: packaging, automotive, medical, electronics, construction and consumer goods. Yet many companies do not have a complete understanding of the chemical composition of their materials.

In an increasingly demanding regulatory context, particularly with the REACH Regulation, this lack of knowledge may represent a significant risk. Are you certain that your polymers contain no regulated substances or substances that may become regulated?

REACH and polymers: what obligations for manufacturers?

The REACH regulation (Registration, Evaluation, Authorisation and Restriction of Chemicals) aims to ensure better protection of human health and the environment against the risks associated with chemical substances.

While polymers currently benefit from a special regime and are not subject to a systematic registration requirement, the monomers, additives, fillers, plasticizers, stabilizers or impurities they contain may be covered by REACH.

In addition, European regulatory developments are gradually strengthening the requirements for traceability and characterization of polymer materials. Manufacturers, importers and users must be able to demonstrate the compliance of their products and anticipate future restrictions.

The risks of incomplete knowledge of your materials

The formulation of a polymer is often complex. Beyond the main matrix, it may include:

  • plasticizers ;
  • flame retardants ;
  • antioxidants ;
  • UV stabilizers ;
  • mineral fillers ;
  • colorants ;
  • synthesis residues or impurities.

Some of these compounds may be present at low concentrations but still pose a major regulatory issue, especially when they are listed as substances of very high concern (SVHC).

Insufficient knowledge of the composition can lead to:

  • supplier audit difficulties ;
  • regulatory non-compliance risks ;
  • export blocks ;
  • product recalls ;
  • loss of trust from customers and contracting authorities.

How can you identify the substances present in a polymer?

Identifying the constituents of a polymer often requires a multi-technique analytical approach. Depending on the nature of the material and the objectives of the study, several methods can be used:

Chemical analysis of additives

Chromatography techniques coupled with mass spectrometry make it possible to identify and quantify numerous organic compounds present in polymer formulations.

Characterization of the polymer matrix

Infrared spectroscopy (FTIR), pyrolysis coupled with GC-MS (Py-GC-MS) or thermal analysis can be used to determine the nature of the polymer and obtain information about its structure.

Targeted search for regulated substances

analysis can be directed toward the detection of specific substances subject to restrictions or declaration requirements under REACH, RoHS or other sector-specific regulations.

Anticipating regulatory changes

The lists of regulated substances change regularly. A formulation that is compliant today may become problematic tomorrow.

Having in-depth knowledge of the composition of your materials makes it possible to:

  • anticipate regulatory changes ;
  • secure your supply chains ;
  • respond quickly to customer requests ;
  • limit industrial and commercial risks.

A proactive characterization approach is therefore a real lever for risk control and competitiveness.

FILAB supports manufacturers in the characterization of their polymers

An independent laboratory based in Dijon, FILAB supports manufacturers in the identification, characterization and analysis of polymer materials.

Thanks to the expertise of its engineers and a state-of-the-art analytical platform, FILAB carries out tailor-made studies to:

  • identify the composition of polymers ;
  • characterize additives and substances present ;
  • search for regulated substances ;
  • support REACH compliance efforts ;
  • investigate contamination issues or material failure.

Would you like to verify the compliance of your materials or better understand their composition? FILAB experts support you in your polymer analysis and characterization projects.

Frequently asked questions

Why identify a polymer’s additives as part of a REACH compliance process?

The nature of the polymer does not describe its entire formulation: plasticisers, stabilisers, fillers or impurities may also raise regulatory concerns. Identifying them helps determine which substances to look for and which requirements to review. The analytical programme depends on the material’s use, its origin and the information available from suppliers.

Does the polymer registration exemption remove all REACH obligations?

Polymers benefit from a registration exemption, but this does not remove all obligations relating to the substances and products concerned. Monomers or other substances may, in particular, need to be registered under certain conditions. Restrictions and information requirements must be assessed according to the composition and intended use. See the ECHA explanations.

Which analyses help provide a better understanding of a polymer’s composition?

FTIR, pyrolysis GC-MS and thermal analysis provide information about the polymer matrix. Chromatography coupled with mass spectrometry can be used to study various organic additives. Targeted quantification completes this characterisation when a specific substance is being sought. The combination of techniques depends on the material and the regulatory or industrial questions being addressed.

What is the difference between formulation characterisation and SVHC screening?

Formulation characterisation aims to describe the constituents that can be detected using the selected techniques. Screening for substances of very high concern targets compounds defined according to the relevant lists and requirements. The two approaches can complement each other, but general screening does not automatically demonstrate the absence of all substances included on a regulatory list.

Why keep the chemical monitoring of polymer materials up to date?

Requirements and substance lists evolve, as do formulations and supply chains. Having traceable composition data makes it easier to assess these changes and target the necessary checks. Supplier declarations, analytical results and information about the product’s use should be cross-referenced to assess the situation of the material concerned.