Polymers (but not the monomers) are exempted from the notification obligation under ChemO and from registration obligation under REACH. Art. 26 para. 1 let. a ChemO exempts polymers as well as substances that are contained as monomer units or chemically bound to the polymer in a concentration of less than 2 percent by weight from the obligation to notify. In order to benefit from this exemption, the polymer must correspond to the definition in art. 2 par. 2 let. g ChemO*. Within the scope of self-regulation, the notifier must check this (in case of uncertainty, he may ask his supplier). He must report polymers within three months of first placing on the market (Art. 48, Art. 19 ChemO), if classified as dangerous. Exceptions: Art. 54 ChemO.

Monomers must be notified if they are placed on the market as such or in the form of a polymer but are not registered in the EU or are registered in a smaller quantity category. Monomers are exempt from the obligation to register if they are registered in the EU in the same or a higher quantity category (status "active", as "INTERMEDIATE", "FULL" or "NONS").

*Polymer means a substance consisting of molecules characterized by the sequence of one or more types of monomer units and comprising:

  1. a simple weight majority of molecules containing at least three monomer units which are covalently bound to at least one other monomer unit or other reactant and
  2. less than a simple weight majority of molecules of the same molecular weight; these molecules must be distributed over a range of molecular weights wherein differences in the molecular weight are primarily attributable to differences in the number of monomer units;

Last modification 21.04.2022

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