Exclusions—Polymers That Must Be on the Inventory

The second condition for the polymer exemption is that the substance cannot be specifically excluded. In practical terms, this means that once a person determines that the substance meets the definition of polymer, he or she must also check the list of exclusions to be certain that the substance is not excluded from the polymer exemption. If the substance is excluded, then no one can manufacture or import it without going through the PMN process. 

There are five types of polymers that are excluded. These are polymers that are cationic or expected to be cationic in the environment polymers with elements outside of specified ranges polymers that degrade, decompose, or depolymerize polymers made from substances that are not on the Inventory and are not otherwise exempt from Inventory listing and heavy polymers that absorb water. 

Cationic polymers were excluded because the EPA was concerned about their ecotoxicity. Cationic polymers are defined in the regulations as  

Cationic polymer means a polymer that contains a net positively charged atom(s) 

Examples of cationic polymers include polymers with phosphonium, sulfo-nium, and ammonium groups. Polymers that are reasonably anticipated to become cationic in the natural aquatic environment, such as in rivers and streams, are also excluded, and this includes polymers with amine or isocyanate groups. 

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