REACH: Consequences for Plastics and Rubbers

REACH regulations concerning the circulation and use of chemicals in the European Community are extremely dense, and even difficult to understand. This document attempts to summarize the regulatory situation with regard to substances used in plastics and rubbers, so that compounders and formulators of these materials are aware of their obligations. Given the large number of substances used in these materials and their specific end-use applications (an aeronautical part has nothing in common with a food-contact part), it is impossible to review all the substances on the list of products of concern (see annexes XIV and XVII of the regulations). This article provides regulatory information on the families of chemical substances more or less concerned with these polymer materials. To date, not all substances have been registered, due to their large number and the current lack of knowledge about the harmfulness of some of them.

In the field of plastic and rubber materials, chemical molecules are produced during the process (known as neoformed substances), which may be poorly defined, or even unknown and potentially toxic, although major studies are underway to identify them. This must be taken into account at the formulation stage to minimize impacts, because although they do not fall directly within the scope of REACH, restrictions may be introduced to protect workers and/or consumers. Part of this article gives recommendations regarding the obligations placed on processors of these materials for consumer goods products.

This article does not deal with requirements relating to the regulation of products in contact with foodstuffs, the transport of drinking water, or products for medical or pharmaceutical use. These are covered by specific, more stringent regulations.