The Measures for the Environmental Management Registration of New Chemical Substances (MEE Order No.12) has entered into force since January 1, 2021. In accordance with its supporting document, the Guidelines for Environmental Management Registration of New Chemical Substances (hereinafter referred to as the “Guidelines”), polymers containing no more than 2% monomers or reactants of new chemical substances or belong to polymers of low concern can apply for records without quantity limitation if they are excluded in exemption circumstances.
The five exemption circumstances for polymer records specified in the Guidelines are:
(1) Cationic polymers or substances that have the possibility of transforming into cationic polymers in a natural water environment;
(2) Degradable or unstable polymers, including polymers that are susceptible to degradation, decomposing, and disaggregation or polymers that will degrade after being manufactured or used; Degradation, decomposition and disaggregation are chemical changes that resolve polymers into substances with simpler and smaller molecular weight after the chemical reactions such as oxidation, hydrolysis, heat, thermal, light, solvent or microorganism;
(3) Water-absorbent polymers whose number-average molecular weight is or above 10,000;
(4) Fluoropolymers whose structure contains fluorinated alkyl; and
(5) Polymers containing elements other than elements permitted besides impurities.
CIRS Group can provide scientific identification of polymers based on their structures and intended uses except for the second circumstance under which auxiliary data is required as supporting evidence.
During the random inspection on the compliance of new chemical substance records, the competent authorities found that applicants only need to submit self-declaration documents without any other supporting documents for the exemption of polymers that are degradable or unstable. Therefore, the competent authorities require applicants to supplement and correct materials and submit identification documents that can prove their stabilities of polymers with the influence of oxidation, heat, thermal, light, solvent, or microorganism within the specified time limit. It is evident that the stability test is becoming an obstacle when applying polymer records.
Currently, Hangzhou C&K Testing Technic Co., Ltd. (C&K Testing), a wholly-owned subsidiary of CIRS Group, has developed different testing methods for polymer degradability and stability. By virtue of these testing methods, CIRS Group is capable to analyze the stability of polymers under different conditions and the testing results can be used as supporting evidence.
CIRS Group is willing to provide solutions to help enterprises resolve difficulties met during applying polymer records and environmental management registrations of new chemical substances in China.
- Stability tests of polymers (such as thermal stability tests; light stability tests; oxidation stability tests; Hydrolytic stability; solvent stability tests; water-absorbability stability tests; and so on);
- Gel Permeation Chromatography (GPC);
- Determination of the exemption circumstances of polymers; and
- Simplified registrations, regular registrations and records of polymers under MEE Order No.12
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