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The Philippines Environmental Management Bureau (EMB) recently published on its website a draft policy regarding polymers and polymer of low concern (PLC) exemption criteria from the Pre-manufacture and pre-importation notification (PMPIN) process (Click here to download). The draft regulation is currently open to public comment.
Current PMPIN exemption rules do mention that “certain polymeric chemical derivatives” can be exempted from PMPIN process, but there seems to be no specific criteria or application requirements for polymers. The draft document details criteria for manufacturers and importers to determine whether their polymer can be exempted.
A polymer can be exempted from PMPIN if it meets any of the following criteria:
All of its monomers are listed in the Philippine Inventory of Chemicals and Chemical Substances (PICCS).
The total quantity of monomers and other reactants (including cross linking, chain transfer agents, and post polymerization reactants) that are not in the PICCS is less than 2 percent (by weight);
The polymer is a polymer of low concern (PLC), which is categorized into 2 types that have different criteria:
Type 1:
Number Average Molecular Weight (NAMW)≥10,000 Da;
Less than 5% of oligomers are with MW lower than 1000 Da and less than 2% of oligomers are with MW lower than 500 Da;
The Functional Group Equivalent Weight (FGEW) for cationic polymers＞5000 Da.
Type 2:
1000Da≦NAMW＜10,000 Da,
Less than 25% of oligomers are with MW lower than 1000 Da and less than 10% of oligomers are with MW lower than 500 Da;
No reactive functional groups are over 2% by weight
To apply for the exemption of the polymers, the manufacturer or importer should submit the following materials:
A duly notarized and accomplished polymer exemption form (signed by the top management i.e., CEO, President, General Manager;
Polymer information like specific chemical name, chemical structure, CAS number (if available), uses of the polymer;
Safety Data Sheet (SDS) for the polymer alone or as isolated as possible;
100% composition including CAS numbers of monomers of the polymer;
Test data or report to prove that the polymer falls in the criteria of low concern polymer (Gel Permeation Chromatography, Infrared Spectroscopy, and others).
EMB allows manufacturers and importers to claim confidential business information (CBI) protection. They should indicate the CBI application in the polymer exemption form. The details for CBI should be provided by the supplier. It should be noted that the authorities won't accept exemption applications during the consultation period of the draft.
