May 27, 2020
The Philippines Environmental Management Bureau (EMB), under the Department of Environment and Natural Resources (DENR), recently published three Memorandum Circulars regarding the Priority Chemicals List (PCL) Compliance Certificate, the Philippine Inventory of Chemicals and Chemical Substances (PICCS) and the application of Pre-Manufacture and Pre-Importation Notification (PMPIN) Compliance.
EMB Memorandum Circular MC No. 2020-005 on Data Requirements For Pre-Manufacture and Pre-Importation Notification (PMPIN) Procedures
EMB Memorandum Circular No. 2020-005, which was issued on February 12, 2020 and took effect fifteen days after its publication, provides further data requirements for the PMPIN process for both the Abbreviated and Detailed forms. The general procedure can be found in Section 3 and specific instructions for each type are found in Annexes A and B respectively. It takes the EMB 90 business days to review the Abbreviated application and 120 business days for Detailed form.
If the PMPIN notifier wishes to apply for Confidential Business Information (CBI), the PMPIN Certificate shall be issued with only the name of the product if the supplier/manufacturer submitted the 100% composition of the imported product and the completed CBI form (Annex C) to the EMB. Submission can occur via mail or email. If a new chemical is in the mixture, the SDS of the product containing the new chemical shall be submitted or updated.
Unless requested for CBI, the new chemical shall be listed in the PICCS a year after receipt of a Notice of Commencement. Exemptions from PMPIN now include:
- Naturally-occurring substances;
- Radioactive substances;
- Finished products such as pesticides, drugs, food and cosmetics.
EMB Memorandum Circular MC No. 2020-007 on Additional Chemicals listed in Philippine Inventory of Chemicals and Chemical Substances (PICCS)
EMB MC No. 2020-007, issued on March 3, 2020, contains a list of 31 chemicals that are included in the PICCS. According to the EMB website, some chemicals including the ones listed in the MC may not show up in the online database due to technical difficulty.
EMB Memorandum Circular MC No. 2020-010 on Clarification to DENR Administrative Order (DAO) 2007-23 on the Scope of Requirements under the Priority Chemicals List (PCL) Compliance Certificate
EMB Memorandum Circular No. 2020-010, which was issued on March 11, 2020 and took effect fifteen days after its publication, clarifies the scope and the title of Section 3.1, 3.2 of DAO 2007-23. The terms ‘importer-distributor, importer-user-manufacturer’ and ‘user-manufacturers’ are replaced with individual terms – importers, distributors, users and manufacturers and any combination of the preceding terms.
The EMB recently developed and published a new Tool for PICCS Validation and determination of RA 6969 Requirements (PICCS Tool) to help importers, distributors, users and manufacturers navigate to the appropriate permits required. The tool is accessible at the Online Permitting and Monitoring System website (after registering and log-in with an account).
Additionally, the Philippines DENR and the EMB currently have several draft regulations available for pubic consultation:
- 3rd Revised Priority Chemical List (on hold)
- Chemical Control Order (CCO) for Cadmium and Cadmium Compounds
- Chemical Control Order for Chromium VI and Chromium VI Compounds
- Guidelines on the implementation of GHS Classification and Labelling Requirements for chemicals under IATA and IMDG
Comments on the regulations can be submitted to the Environmental Management Bureau (EMB) via phone at (02)928-8892 or via e-mail at [email protected]
EMB MC No. 2020-005 on Data Requirements For Pre-Manufacture and Pre-Importation Notification (PMPIN) Procedures: http://chemical.emb.gov.ph/wp-content/uploads/2020/05/EMB-MC-2020-005_DATA-REQUIREMENTS-FOR-PMPIN-PROCEDURES.pdf
EMB MC No. 2020-007 – Additional Chemicals in Philippine Inventory of Chemicals and Chemical Substances (PICCS): http://chemical.emb.gov.ph/wp-content/uploads/2020/05/EMB-MC-2020-007.pdf
EMB Memorandum Circular MC No. 2020-010 on Clarification to DENR Administrative Order (DAO) 2007-23 on the Scope of Requirements under the Priority Chemicals List (PCL) Compliance Certificate: http://chemical.emb.gov.ph/wp-content/uploads/2020/05/EMB-MC-2020-010.pdf
Online Database of PICCS: http://18.104.22.168/internal/CasREgistry.aspx
Online Permitting and Monitoring System website: https://opms.emb.gov.ph/accounts/login/
DENR and EMB draft regulations: http://chemical.emb.gov.ph/