SQI AND POLEX

DEPARTMENT OF ENVIRONMENT AND

NATURAL RESOURCES
ENVIRONMENTAL MANAGEMENT BUREAU
Pre-Manufacture & Pre-Importation
Notification (PMPIN) Process

SQI
CLEARANCE

NEW PMPIN
CHEMICAL CERTIFICATE

POLYMER
EXEMPTION
CERTIFICATE
SMALL QUANTITY
IMPORTATION CLEARANCE
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
ENVIRONMENTAL MANAGEMENT BUREAU
REPUBLIC ACT 6969
Toxic Substances and Hazardous and
Nuclear Wastes Control Act of 1990

DENR ADMINISTRATIVE ORDER 1992-29

Implementing Rules and Regulations
of Republic Act 6969
DENR ADMINISTRATIVE ORDER 1992-29
Sec. 22. Exemptions
The following substances and mixtures shall be exempted from the requirements of
Section 17, 18, and 21 of these Rules and Regulations:

Those chemicals already included in the Philippine Inventory of Chemicals and

Chemical Substances (PICCS);

Those to be produced or used in small quantities solely for experimental or research and
development purposes;

Those that are reaction intermediates which do not leave the closed production system
or undergo intermediate storage during the reaction process; and

Those chemical substances that are regulated by laws other than RA 6969.
EMB MEMORANDUM 2003
Guidelines on Small Quantity Importation under
RA 6969 and its IRR

Small Quantity Importation (SQI)

- amount of "new chemical substance" (as defined by RA 6969) which
shall not exceed 1000 kg/yr as:

1. Pure chemical substance; or

2. Component (in wt %) of a product, mixture, etc.
EMB MEMORANDUM 2003
Guidelines on Small Quantity Importation under
RA 6969 and its IRR

Applicants for SQI of a new chemical substance shall be required to

submit or undertake the following:

Identify the new chemical substance by chemical name, CAS RN, and
structure.
Indicate the percentage of the new chemical substance in the
product/mixture. If expressed in ranges, the upper limit shall be used.
Submit information on the annual amount (in kg) of the
product/mixture containing the new chemical substance.
Submit PMPIN Certificate if the amount exceeds SQI criteria.
MAXIMUM QUANTITY ALLOWED FOR MIXTURES

1000 kg
Max. Qty. =
Percentage of new chemical
(in decimal form)
EMB MEMORANDUM CIRCULAR 2016-011
SQI Clearance is not required for products that are ready to use and no
longer require further processing to be sold into the consumer market.
Exemption shall not include substances and products to be used for
industrial operations.

Only one (1) SQI Clearance per chemical substance/mixture shall be

issued for a year.

SQI Clearance shall be renewed for a maximum of five (5) years and
shall include the first year when companies secured their SQI
Clearances. After which, PMPIN shall be applied.
SUMMARY
SQI - new chemical substances/mixtures not exceeding 1000 kg/yr.

Required Information: chemical name, CAS RN, percentage of new

chemical, annual amount of chemical substance/mixture.

Maximum allowable quantity = 1000 kg / % of new chemical

Only one (1) SQI Clearance per chemical substance/mixture shall be

issued for a year.

SQI Clearance shall be renewed for a maximum of five (5) years.

Initial application shall be considered as the 1st year.
Pre-Manufacture & Pre-Importation
Notification (PMPIN) Process

SQI
CLEARANCE

NEW PMPIN
CHEMICAL CERTIFICATE

POLYMER
EXEMPTION
CERTIFICATE
POLYMER EXEMPTION
DEPARTMENT OF ENVIRONMENT AND
NATURAL RESOURCES
ENVIRONMENTAL MANAGEMENT BUREAU
DENR ADMINISTRATIVE ORDER 2019-18
Polymers and Polymers of Low Concern
(PLC) Exemption from the PMPIN Process
Polymer
A substance composed of more than 50% (w/w) of molecules containing a sequence of at
least three monomer units covalently bound to at least one other monomer unit or other
reactant.
Has molecules distributed over a range of MW.
Has no single MW molecule reaching 50% (w/w) of total molecules.

Polymer of Low Concern (PLC)

Must meet the definition of Polymers.
Must meet criteria under Section 4.4a or Section 4.4b.
Must not be unstable, degradable, decompose, or depolymerize.
DENR ADMINISTRATIVE ORDER 2019-18
Polymers and Polymers of Low Concern
(PLC) Exemption from the PMPIN Process
Number Average Molecular Weight (NAMW)
The arithmetic mean average of the molecular weight of all the molecules in the polymer,
not taking into account unreacted monomers and other reactants, but must include
oligomers.

Cationic Polymers
A polymer containing a net positively charged atom/s or associated group/s of atoms
covalently linked to its polymer molecule (e.g. ammonium, phosphonium, sulfonium
cations).
DENR ADMINISTRATIVE ORDER 2019-18
Polymers and Polymers of Low Concern
(PLC) Exemption from the PMPIN Process
Functional Group Equivalent Weight (FGEW)
The ratio of the NAMW to the number of functional groups in the polymer. It is the weight of
a polymer that contains one formula weight of the functional group.

Reactive Functional Group (RFG)

An atom or associated group of atoms in a chemical substance that is intended or can be
reasonably anticipated to undergo facile chemical reaction.
DENR ADMINISTRATIVE ORDER 2019-18
Section 4. Criteria for Polymer Exemption from PMPIN Process
The Polymer should meet any of the following criteria:

1. All of its monomers must be listed in the PICCS.

2. Polymers containing monomers and other reactants not in the PICCS

added at quantities less than 2 percent (by weight).

3. A new polymer if two or more of the top (by weight) monomers are
included in the definition of another polymer already in the PICCS.
DENR ADMINISTRATIVE ORDER 2019-18
Section 4. Criteria for Polymer Exemption from PMPIN Process
The Polymer should meet any of the following criteria:

4. The PLC shall fall into one of the conditions:

a. Polymers that have:

Number Average Molecular Weight (NAMW) equal to or greater than
10,000 Da.

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

For cationic polymers, the FGEW should be greater than 5,000 Da.
DENR ADMINISTRATIVE ORDER 2019-18
Section 4. Criteria for Polymer Exemption from PMPIN Process
The Polymer should meet any of the following criteria:

4. The PLC shall fall into one of the conditions:

b. Polymers that have:

NAMW equal to or greater than 1,000 Da and less than 10,000 Da.

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

No RFGs in excess of the levels of 2% by weight.

DENR ADMINISTRATIVE ORDER 2019-18
Section 5. Requirements for Application
Duly accomplished and notarized Polymer Exemption form.
Polymer information:
Chemical Name
Chemical Structure
CAS RN
Use/s of Polymer
SDS for the polymer alone or the mixture/product where the polymer is
part of the ingredients.
100% composition of the Polymer including CAS RN of monomers and
other reactants.
Data requirements that show proof that the polymer meets any of the
conditions stated in Section 4.
 SQI POLEX

Case Handlers Regional Office Central Office

Processing Time 20 Working Days 20 Working Days

Application Fee 600 php 1500 php

RO Email /
CBI chemicals@emb.gov.ph
chemicals@emb.gov.ph

Validity 1 Year (max. 5) One-time Application

THANK YOU