Polymer dispersions are mixtures as defined under Article 3(2) of the REACH Regulation, consisting mainly of water and high molecular weight polymer droplets. They are also subject to Regulation 1272/2008 EC (CLP) where applicable. Article 45 of the CLP regulation ‘required the EU Member States to appoint a body for receiving information on the composition of hazardous mixtures to enable the formulation of preventive and curative measures.’ After consultation with the stakeholders Commission Regulation (EU) 2017/542 was adopted, adding Annex VIII to the Regulation.
Annex VIII of CLP requires the submission of information about mixtures that are placed on the EU market and are classified as hazardous based on their health or physical effects. It means that all mixtures meeting the criteria defined in Part 2 and Part 3 of Annex I of CLP fall under the scope of Article 45 and Annex VIII. Among the mixtures which fall under the scope of the CLP Regulation, some exemptions apply:
- mixtures classified for environmental hazards only;
- mixtures which are subject to supplemental labelling requirements according to Part 2 of Annex II to CLP (i.e. EUH 208) but are not themselves classified for health or physical hazards. Polymer dispersions fall mainly under the category of non-classified mixtures (with rather few exceptions mainly related to the presence of some additives i.e. biocides, residual monomers etc.) and are therefore, exempted from submission obligations.