Implications, exemption regulations

The Carra Letter went on to address the implications of making a yarn treatment product before it is added to the yarn to which it will provide antistatic properties. If a salt form of antistatic agent is made by pH neutralization of an acid precursor during the formulation process of making the yarn treatment product, then the salt does provide a primary purpose of the yarn treatment product, and it is not exempt from the Inventory and PMN regulations. This is the case even if other yarn treatment ingredients are present in the formulation when the acid precursor is neutralized. The distinction between this example and the polymer salt example is that the polymer salts were made as part of the ink formulation and do not contribute a primary performance characteristic of ink, but in this example the acid is made as part of a product that is intended only as a yarn treatment and it does contribute one of the primary performance characteristics of the yarn treatment product. 

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