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On June 14, 2019, the Chemical Safety Support Team (https://www.chemnavi.or.kr/) under the South Korean Ministry of Environment gave explanations on the pre-registration of polymers in existing chemical substances. [1]
(1) For polymers with the same monomers (except monomers with a weight ratio of less than 2%), they can be pre-registered as polymers with the same official number.
When proceeding the follow-up registration of such polymers, manufacturers or importers should jointly submit application information such as their physical and chemical properties, similarities, and labels. Where there are differences in classification, labels, or data of the same experiment, manufacturers or importers can submit their pre-registration application separately or form a consortium to apply for pre-registration after obtaining the approval for separate submission.
For polymers which contain monomers with a weight ratio of less than 2% in their names and have other official numbers or substance names, if businesses want to use such numbers or names, they can get the substances pre-registered or registered with the numbers.
(2) Some substances with the same official number, can be identified as either polymers or general chemical substances. Businesses should get such substances pre-registered separately. Their information such as volumes, use, classification, and labels should all be confirmed and submitted separately.
Where it is hard to identify whether a substance is a polymer or a general chemical substance in this case, businesses can count its manufacture or import volumes and get it pre-registered as polymer or general chemical substance with the confirmed information.
(3) Manufacturers or importers should get polymers pre-registered within the time limit with as much information as can be confirmed (information required for pre-registration, such as their classification, labels, and use). Supplementary information can be submitted in the follow-up procedures.
If multiple classifications and labels are identified based on information like the range of average molecular weight, businesses should record and submit the most conservative figures.
