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Important to note: The entire group of fluorinated polymers will be generally defined to be PRR independent of other properties of the polymers. The Commission’s concerns are:
- that problematic fluorine-containing processing aids, monomers, oligomers, smaller polymer fractions and by-products can be emitted during production and use of fluoropolymers into the environment, and
- that no safe end-of-life treatment is known for all these polymers and that they are not recyclable.
This may also have an impact on the currently planned PFAS restriction proposal.
Please follow the link to view the updated flow-chart for the PRR criteria.
PRRs are divided into three groups, which are defined by the molecular weight of the polymer. Low molecular weight polymers (MW below 1000 da) have the same study requirements as substances under REACH. Group 2 and 3 polymers require less data. The EU Commission also gives guidance on measurement of (eco-)toxicological parameters. For high molecular weight and insoluble polymers, testing will need to be done on leachates from the polymers to cover residual monomers, oligomers and other by-products. The extract should be prepared using OECD TG 120.
It is important to note that these new developments are not yet fixed and subject to current discussions in the upcoming meetings of the CARACAL subgroup.