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Philippine DENR Issues Order for Polymer and PLC Exemption from PMPIN

The Philippine DENR specified the criteria and requirements for the exemption of polymers and PLCs from the PMPIN process.

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).

Specifically, to be exempt from the PMPIN requirements, polymers should satisfy any of the following requirements:

1. All of its monomers should be listed in the PICCS;

2. 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)

3. 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 (a new addition compared to the consultation paper)

4. For PLCs, they should fall under either of the following two categories:

    Category 1

    • Number Average Molecular Weight (NAMW) ≥10,000 Da;

    • Less than 5% of oligomers are with Molecular Weight (MW) lower than 1,000 Da and less than 2% of oligomers with MW lower than 500 Da; and

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

    Category 2

    • 1,000Da ≦NAMW<10,000 Da;

    • 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;

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

To apply for exemption of polymers or PLCs, manufacturers or importers should submit the following documents or items:

  • Duly notarized and accomplished polymer exemption form;

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

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

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

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

  • Request for confidential business information through an official letter with justification

  • Processing fee amounting to Php 1,500.00

The Lists of RFGs and Reactants are attached to the Administrative Order as Annexes I and II to provide further guidance for manufacturers and importers of polymers and PLCs.

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