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Interpretation of Polymer and PLC Exemption Rules in the Philippines

This news piece clarifies requirements of Pre-Manufacture and Pre-Importation Notification (PMPIN) exemption which can be granted to importers and manufacturers of certain polymers and polymers of low concern (PLCs).

On November 8, 2019, the Philippine Department of Environment and Natural Resources (DENR) issued the Administrative Order for Polymers and Polymer of Low Concern Exemption from the PMPIN Process [1], aiming to grant Pre-Manufacture and Pre-Importation Notification (PMPIN) exemption to importers and manufacturers of polymers and polymers of low concern (PLCs).

The administrative order took effect 15 days after it was gazetted. The central office of the Environmental Management Bureau (EMB) under the DENR began accepting applications for polymer exemption on January 6 this year.

Application

For new polymers which are not listed in the Philippine Inventory of Chemicals & Chemical Substances (PICCS), their importers and manufacturers are exempted from PMPIN requirements as long as they meet certain conditions.

Details of Polymer Exemption Rules

Definition   of polymer

l  Substance of which the molecular weight is defined as a   distribution rather than a specific number

l  Substance composed of more than 50% (by weight) of molecules   containing a sequence of at least three monomer units covalently bound to at   least one other monomer unit or other reactant

l  The amount of molecules of any single molecular weight does not   exceed 50% (by weight) of total molecules.

Four   circumstances of exemption

l  All monomers of a polymer are listed in the PICCS

l  The total quantity of monomers and other reactants (including cross linking, chain transfer agents, and post polymerization reactants)   which are not listed in the PICCS is less than 2% (by weight)

l  A new polymer if two or more of the top (by weight) monomers are   included in the definition of another polymer listed in the PICCS

l  PLCs

Definition  of PLC

l  Category 1 

Ø  Number Average Molecular Weight (NAMW) 10,000 Da,

Ø  Less than 5% of oligomers are with MW lower than 1,000 Da and less   than 2% of oligomers with MW lower than 500 Da; and

Ø  Functional Group Equivalent Weight (FGEW) for cationic polymers 5,000 Da.

 

l  Category 2

Ø  1,000Da NAMW<10,000 Da

Ø  Less than 25% of oligomers are with MW lower than 1,000 Da and   less than 10% of oligomers with MW lower than 500 Da; and

Ø  No reactive functional groups (RFGs) are over 2% by weight.

Document Requirements for Polymer Exemption

l  Application form for polymer exemption;

l  Polymer information like specific chemical name, chemical structure, CAS number (if available), and uses of the polymer;

l  Safety Data Sheet (SDS) for the polymer alone or a mixture/product where the polymer is part of the composition;

l  100% composition including CAS numbers of monomers and other reactants;

l  Data which can prove that the polymer or PLC satisfies any of the conditions above (Gel Permeation Chromatography, Infrared Spectroscopy, etc.);

l  Request for confidential business information through an official letter with justification.

Other Key Points to be Noted

l  Polymers which have been granted with exemption are not subject to this administrative order

l  The processing fee amounts to PHP 1,500

l  The application will be processed within 20 working days from receipt of relevant documents

l  Any exempted polymers will not be listed in the PICCS

Penalties

Where any false or fabricated information is identified in the application, the exemption certificate granted will be revoked, and the applicant involved will be subject to administrative punishment and fines of PHP 10,000-50,000.

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