The OECD provides an update on Polymers of Low Concern (PLC)

1. OECD COMMUNICATION ON
POLYMERS OF LOW CONCERN
January 2024

2. • Three meetings of the OECD Expert Group on Polymer Definitions
held in 1990, 1991, and 1993
– Developed consideration for polymers of low concern to aid countries in
decision-making
– Seven main criteria were discussed
– Specific parameters for each criterion were not agreed at the OECD
• Several countries implemented criteria for reduced regulatory
requirements for polymers
– Australia, Canada, Japan, Korea, New Zealand and the United States
• Not all implemented them in the same way
Background (1)

3. PLC criteria used in different jurisdictions
Groh et al. 2023. https://doi.org/10.1039/D2EM00386D
Source: Reproduced from Environ. Sci.: Processes Impacts, 2023,25,10-25 via the Creative Commons CC BY-NC 3.0 licence

4. • 2007 OECD Expert Group Meeting of Expert Group on polymers under Task Force on New
Chemicals Notification and Assessment
– held in Tokyo, Japan.
– meeting was organised to share information and consider commonalities in criteria and
approaches
• EG recommended an analysis of data submitted to OECD regulatory authorities to identify
correlations between polymer characteristics and potential for health or ecotoxicological
concern
– Led by Australia (2007-2008) For polymers that met the PLC criteria, 87.8% showed low health
concern and/or low ecotoxicological concern.
– Data were of variable quality and it was not possible to critically evaluate health concerns that
were reported
– examination of specific effects was not possible
– Report published in 2009 ENV/JM/MONO(2009)1
• No subsequent work at OECD
Background (2)

5. • Several scientific papers review criteria used
• Include additional criteria not included in PLC criteria
– Lipophilicity
– Particle size/respirability
– Production volume
– Intended uses
• Additional criteria used in some jurisdictions
– Hazard classification
– Fluorinated polymers
– Water absorption
– Unreacted monomers
– Surface activity
External work

6. Recent attention because:
1. EU is discussing introducing reporting requirements for polymers under REACH
regulation
• Many of the elements under consideration for identifying polymers requiring registration under
REACH draw from the application of criteria in other countries.
• In addition, recent science in this area has been highlighted.
• Criteria not used to identify PLC but identify polymers requiring registration
2. Many countries are planning to regulate PFAS and need to decide on how to deal with
fluoropolymers.
• OECD criteria for PLC have been applied to justify low concern for fluoropolymers.
• There is not agreement that they are of low concern or that all fluoropolymers meet the criteria.
3. Initial negotiations on international legal instrument to reduce plastic pollution
• In this context, criteria for PLC needed
Current issues

7.  Many regulatory approaches were based on the early 1990s OECD
work, which is still frequently cited.
 Given the experience in many countries with varied application
applying criteria and recent scientific advances in this area,
 OECD recommends the regulatory schemes of individual countries
should be consulted.
OECD Recommendations