Polymers come in many different forms and are often used in a vast range of applications within EU Fertilising products. There are also, internationally, varying definitions for polymers.
FPR does not have a strict definition of a polymer, and so whilst it is advised to use the REACH definition of a polymer (inserted below), there is some room for interpretation and it is not explicit in the FPR that the REACH definition of a polymer should be used. .
Regulation 1907/2006 (REACH) article 3 (5):
polymer: means a substance consisting of molecules characterised by the sequence of one or more types of monomer units. Such 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. A polymer comprises the following:
(a)
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;
(b)
less than a simple weight majority of molecules of the same molecular weight.
In the context of this definition a ‘monomer unit’ means the reacted form of a monomer substance in a polymer;
Polymers are exempted from REACH registration and so the REACH+ requirements does not apply to these polymers. In case of CMC 8 Nutrient Polymers however FPR requires the nutrient monomers to to be REACH registered.
FPR has created room for polymers in different CMC's. The choice is up to the manufacturer, so sometimes there is a case to be made for 2 CMC's and the manufacturer must decide. Mostly however the function of the polymer will decide the CMC.
Below we highlight the options for Polymers in FPR.
CMC 1
Any polymer can fall under CMC 1 as long as it complies with 1 of the below criteria:
CMC 8
If you have a Nutrient Polymer the monomers must comply with the EU FPR REACH+ requirements meaning you must document their registration. The purpose of the polymer must be to control the release of nutrients from one or multiple monomer substances. If your polymer complies with the below requirments it can fall under CMC 8.
- At least 60 % of the polymers shall be soluble in a phosphate buffer solution with a pH of 7,5 at 100 °C.
- The final degradation products shall be only ammonia (NH3), water and carbon dioxide (CO2).
- The polymers shall not contain more than 600 ppm of free formaldehyde.
CMC 9
If your polymer controls water penetration (its a coating agent), increases the water retention capacity or wettability of a fertilising product or is a binder for growing media it falls under CMC 9.
All CMC 9 polymers except binders must subject themselves to three tests, which if they comply with allow them to be used as a CMC 9 polymer in EU fertilising products:
- Earthwork acute toxicity test
- Plant growth acute toxicity test
- Nitrification inhibition test with soil-microorganisms
Contact us and we can provide you with more information, or perhaps you already have test reports from your suppliers: Can my supplier provide the study report for CMC 9?
Key change!
From 2026 there will be new rules for Biodegradability of polymers. The initiative aims at introducing the same biodegradability criteria for polymers (other than coating and water retention agents) in EU fertilising products as those set out by the restriction on intentionally added microplastics in national fertilising products set out in the REACH Regulation.
The draft criteria have since been published here: https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13898-EU-fertilising-products-Aligning-biodegradability-criteria-for-polymers-to-the-REACH-restriction-on-microplastics_enWas this article helpful?
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