CAS 9002-86-2 · REACH · European Union

Polyvinyl chloride under REACH

(C2H3Cl)n · 聚氯乙烯

Status: Exempt. Polyvinyl chloride is a polymer and is currently EXEMPT from REACH registration under Article 2(9) (polymer exemption); the constituent monomer (vinyl chloride monomer, VCM, CAS 75-01-4) IS fully registered as a CMR Cat 1A carcinogen substance. The EU Polymer Strategy under REACH revision (Polymer of Concern criteria, expected 2026-2027) is moving toward polymer registration; PVC is one of the most-scrutinised candidates for future polymer registration. Plasticisers commonly used in flexible PVC formulations (DEHP, DBP, BBP, DIBP) are SVHC and Annex XIV-listed authorisation substances.

PVC is the polymer archetype: REACH-exempt under Article 2(9) polymer exemption. The constituent VCM monomer is REACH-registered and SVHC candidate-list designated as Carcinogen Cat 1A, but is NOT on Annex XIV (Authorisation list) as of audit date 2026-05-09 (verified against ReachOnline.eu). The compliance work is structurally different from the small-molecule chemicals (NaOH, sulfuric, methanol, HCl, MEG, PTA, etc.): verify upstream VCM registration, verify plasticiser composition vs Annex XIV (DEHP entry 4 / BBP entry 5 / DBP entry 6 / DIBP entry 7, all sunset 21 February 2015 per ECHA Annex XIV list), and verify food-contact resin meets Reg 10/2011 residual VCM SML. The EU Polymer Strategy revision (2026-2027 timeline) is the dominant medium-term watch-item; PVC is one of the most-scrutinised polymer candidates for future REACH polymer registration. Coal-route Chinese PVC (calcium carbide chain) carries Minamata Convention mercury-catalyst concern that some EU buyers factor into supplier selection.

Listing and threshold

Substance Polyvinyl chloride (CAS 9002-86-2), (C2H3Cl)n
Regime EU Regulation (EC) No 1907/2006: Registration, Evaluation, Authorisation and Restriction of Chemicals
Jurisdiction European Union (EU-27 plus EEA: Iceland, Liechtenstein, Norway)
Status Exempt
Tonnage threshold Polymer exemption applies; constituent VCM monomer registered separately at >1,000,000 tonnes/year band

Classifications under this regime

  • Polymer NOT subject to REACH registration under Article 2(9) polymer exemption (Title II Registration and Title VI Evaluation do not apply to polymers; monomers and other substances comprising the polymer are still registrable if >=2 percent w/w monomeric units and total >=1 t/yr; verified against https://www.cirs-reach.com/REACH/Polymer_REACH_CLP.html)
  • Constituent monomer VCM (CAS 75-01-4) carries harmonised CLP Carcinogen Cat 1A (H350, "may cause cancer"), Flam. Gas 1 (H220), Press. Gas
  • Constituent monomer VCM (CAS 75-01-4) carries SVHC candidate-list designation (CMR Cat 1A); NOT on REACH Annex XIV (Authorisation List) as of audit date 2026-05-09 (verified against ReachOnline.eu Annex XIV table; the SVHC candidate list and the Annex XIV authorisation list are different lists)
  • Finished PVC resin: NOT classified as hazardous (residual VCM in resin spec ≤1 ppm under EN 13130)
  • GHS pictograms for finished PVC: NONE typically required
  • Plasticiser additives (DEHP entry 4 / BBP entry 5 / DBP entry 6 / DIBP entry 7 per ECHA Annex XIV list, all sunset 21 February 2015): SVHC and Annex XIV authorisation substances; regulated separately from PVC polymer. Verify against https://echa.europa.eu/authorisation-list
  • IARC: VCM Group 1 (carcinogenic to humans, IARC Monograph 100F, 2012); finished PVC resin not separately evaluated

Restrictions and conditions of use

  • Polymer EXEMPT from REACH registration under Article 2(9); EU Polymer Strategy moving toward polymer registration in 2026-2027 timeline
  • Vinyl chloride monomer (VCM, CAS 75-01-4) is REACH-registered as a CMR Cat 1A substance and is on the SVHC candidate list, but NOT on REACH Annex XIV (Authorisation list) as of audit date 2026-05-09. The intermediate-use derogation under Article 2(8)(b) applies to on-site isolated and transported intermediates regardless of Annex XIV status. Verify current Annex XIV status against https://echa.europa.eu/authorisation-list before drafting compliance plans
  • Annex XVII Restriction 51 (DEHP, DBP, BBP, DIBP plasticisers): mixtures and articles containing >0.1% by weight prohibited from many uses (toys, childcare articles, food-contact); verify specific scope and exemptions against https://reachonline.eu/reach/en/annex-xvii.html
  • Annex XVII Restriction 52 (DINP, DIDP, DNOP plasticisers in toys and childcare articles intended to be placed in the mouth): prohibited above 0.1%; verify specific scope against https://reachonline.eu/reach/en/annex-xvii.html
  • EU Regulation 10/2011 (Plastics Implementing Regulation) sets specific migration limits for residual VCM in food-contact PVC resin (SML 0.01 mg/kg food)
  • EU Single-Use Plastics Directive (SUP, Directive 2019/904) restricts certain single-use PVC items
  • Carbon Border Adjustment Mechanism (CBAM): PVC is NOT in CBAM Phase 1 scope (cement, iron and steel, aluminium, fertilisers, hydrogen, electricity (Phase 1 scope verified at https://taxation-customs.ec.europa.eu/carbon-border-adjustment-mechanism_en, definitive period from 1 January 2026))

Importer obligations

A non-EU producer cannot register PVC under REACH (polymer exempt) but the EU importer of record must verify VCM upstream registration through the supply chain. The compliance work is structurally different from monomer chemicals: (1) verify VCM monomer is REACH-registered upstream, (2) verify any plasticisers in flexible-PVC formulations are NOT Annex XIV-listed (or are authorised); DEHP entry 4, BBP entry 5, DBP entry 6, DIBP entry 7 are all on Annex XIV with sunset date 21 February 2015 per ECHA, (3) verify residual VCM in food-contact resin meets EU 10/2011 SML limits. The EU Polymer Strategy revision is a watch-item for 2026-2027 timeline; medium-term planning should assume polymer registration may apply to PVC.

Required documents

  • Upstream VCM REACH registration verification through supply chain
  • Safety Data Sheet (SDS) compliant with REACH Annex II (even though polymer is exempt, downstream user information must be provided)
  • Plasticiser composition declaration (DEHP, DBP, BBP, DIBP NOT present, OR proper Annex XIV authorisation if present)
  • Customs entry with HS code 39041000 (PVC primary form, not plasticised) or 39042100 (plasticised) or 39043000 (other vinyl chloride copolymers)
  • EU Regulation 10/2011 Plastics Implementing Regulation compliance documentation for food-contact applications
  • EU CE marking for construction PVC products (windows, profiles, pipes) per Construction Products Regulation (EU) 305/2011

Common compliance traps

The pitfalls that have bitten importers on this lane in the past. None of these is theoretical.

  • EU Polymer Strategy is the medium-term watch-item: REACH revision is moving toward polymer registration in 2026-2027 timeline; PVC is a high-priority candidate; downstream importers should plan for compliance pivot
  • Plasticiser migration in flexible PVC is the dominant SVHC compliance risk; verify plasticiser composition vs Annex XIV and Annex XVII Restrictions 51/52
  • Coal-route Chinese PVC (calcium carbide chain) carries Minamata Convention compliance concern: mercury catalyst used in acetylene-to-VCM conversion; some EU buyers refuse coal-route PVC on Scope 3 carbon and mercury concerns
  • EU Single-Use Plastics Directive restricts certain single-use PVC items; verify finished-product compliance at EU border
  • EU food-contact PVC residual VCM SML limit (0.01 mg/kg food per Reg 10/2011) is technically demanding; major Chinese producers (Sinopec, Wanhua, Tianjin Dagu, LG Chem Daya Bay) routinely meet but smaller producers may not
  • NO active EU AD/CVD case on Chinese-origin PVC currently. EU has had AD investigations on PVC blends and certain end-products (resilient flooring containing PVC) but no active orders on bulk PVC primary form
  • NOT in CBAM Phase 1 scope but EU revisions may extend to organic chemicals; long-term watch-item

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for polyvinyl chloride, see the CAS 9002-86-2 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the polyvinyl chloride cornerstone hub covers the full sourcing chain.

For the structure and history of REACH, see the REACH glossary entry.

Need cross-jurisdiction compliance support on this substance? Run it through the REACH / TSCA / IECSC / AICIS / K-REACH checker, or send us the substance and the destination and we will quote FOB China and CIF / DDP landed including the regulatory work on the destination side.

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Cross-jurisdiction profile and sourcing references

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