Record keeping for exempted introductions – polymers that are comparable to listed polymers

Before you read this page’s content, make sure you’ve already read and understood:

• why you must keep records
• written undertakings as records (if you’ve relied on information held by another person — such as a supplier or manufacturer — to categorise your introduction)

Go to our record-keeping overview page for this information.

Records you must keep

The type of records you must keep depends on:

• whether you know the CAS number or the proper name (CAS, IUPAC or INCI for plant extracts under certain criteria) for your chemical
• when you first introduced your polymer.

Work through the information on this page to understand your record-keeping obligations for this type of introduction.

Records you must keep if you first introduced your polymer on or after 1 July 2020

Chemical identity

• If you know the CAS number – written or electronic record of the CAS number and either the CAS name or INCI name for the chemical.
• If you don’t know the CAS number – you must have either A or B.
  
  A. Written or electronic record of the CAS name or IUPAC name. An INCI name can only be used if the chemical and its name meet all 4 criteria:
  
  i. the chemical does not have a CAS or IUPAC name 
  
  ii. the chemical is a plant extract – examples are extracts of flowers, seeds, or leaves of trees, shrubs, herbs, grasses, ferns, and mosses
  
  iii. the name of the plant extract is an INCI name based on a proper botanical name – for example, 'Helianthus Annus Leaf/Stem Extract' is acceptable but 'Sunflower extract' is not acceptable.
  
  iv. the plant extract cannot be chemically modified – for example, the chemical cannot be hydrolysed, acetylated, or hydrogenated.
  
  B. Written or electronic record of the names you use to refer to your chemical and a written undertaking from the supplier or manufacturer that they will give us the proper name (CAS or IUPAC) and CAS number (if assigned) if we ask for them.

Polymer criteria

If you don’t know the proper name – a written undertaking from the supplier or manufacturer confirming each of the following items. They must provide records to prove each of the following items, if we ask for them.

• Records to prove your chemical meets our definition of a polymer. We’ll accept a GPC analysis report. 
• Records to prove that your polymer:
  • contains each of the reactants that another polymer that is listed on the Inventory (the listed polymer) does; and 
  • contains one or more other reactants (the additional reactants) that the listed polymer does not and that each additional reactant does not constitute more than 2% by weight of your polymer.

See our definition of a polymer.

View our polymer of low concern criteria page if you need help or more information about any of the above. 

Introduction requirements

If you don’t know the proper name – a written undertaking from the supplier or manufacturer confirming each of the following items. They must provide records to prove each of the following items if we ask for them.

• Records to prove your polymer:
  • isn’t listed in Annex III of the Rotterdam Convention or Part 1 of Annex A, B or C of the Stockholm Convention on POPs (unless it is introduced solely for use in research or analysis and the amount that you introduce in a registration year does not exceed 100kg)
  • isn’t listed on the Inventory with conditions of introduction or use that will be contravened.
    
    We’ll accept a signed and dated declaration that these checks took place.
• If the terms of the Inventory listing for the listed polymer include a defined scope of assessment – records to prove that you are introducing or using your polymer in accordance with that defined scope. The information that we’ll accept depends on the defined scope of assessment.
• If the terms of the Inventory listing for the listed polymer include conditions relating to its introduction or use – records to prove you are complying with those conditions for your polymer. The information that we’ll accept depends on the conditions relating to its introduction or use.
• If the terms of the Inventory listing for the listed polymer include specific requirements to give us information – records to prove that you are meeting those requirements for your polymer. The information that we’ll accept depends on the specific requirements.

Records you must keep if you first introduced your polymer before 1 July 2020

The records you must keep relate to the chemical identity of the polymer that is listed on the Inventory (the listed polymer) that is comparable to your polymer – rather than the polymer you are introducing. 

• If you know the CAS name and CAS number of the listed polymer, you must keep records of these.
• If you do not know the CAS name and CAS number of the listed polymer, you must keep records of:
  • the names you use to refer to the listed polymer; and
  • a written undertaking from the supplier or manufacturer that they will give us the CAS name and CAS number (if assigned) if we ask for them