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China REACH
On February 7, 2021, Shanghai Municipal Bureau of Ecology and Environment released a notice regarding Strengthening the Supervision on Enterprises in Environmental Management of New Chemicals, in which the Bureau mentioned that it is to enhance the daily environmental management of new chemicals, improve the on-site supervision of environmental enforcement on new chemicals, implement policies and regulations on new chemicals and conduct law enforcement inspections annually.
The Measures on the Environmental Management Registration of New Chemical Substances (MEE Order 12) were implemented two years ago on January 1, 2021. It has not only optimized and adjusted the registration types and relevant data requirements to lessen the burden on enterprises, but also focused on environmental risk prevention and control for new chemical substances with high environmental risks. In addition, MEE Order 12 has specified the registration standards and improved the approval requirements for new chemical substances in the review and evaluation, stating the specific circumstances for approval, disapproval, reapplication, change, withdrawal, and revocation of registrations.
Shanghai has numerous chemical-related enterprises, including manufacturers and importers. Chemical enterprises and downstream users in the city are the first to be inspected in the annual environmental enforcement inspections. To avoid being punished for violating the Measures for the Environmental Management Registration of New Chemical Substances (MEE Order 12), enterprises need to formulate strategies to properly cope with the law enforcement inspections.
On December 5, 2022, China's Ministry of Ecological Environment (MEE) announced the addition of a batch of six substances that fulfill the requirements of existing substances for inclusion in the IECSC. These six substances were all manufactured, sold, processed in, or imported into China before October 15, 2003. Following its review of the application materials and evidence documents submitted by the applicant, the MEE believed that these substances fulfill the requirements for IECSC supplementation.
On December 5, 2022, China's Ministry of Ecological Environment (MEE) announced the addition of a batch of 36 substances that fulfill the requirements of existing substances into the Inventory of Existing Chemical Substances Produced or Imported in China (IECSC). These 36 substances were all registered under the original MEP Order 7 and five years have passed since they reported their first activity.
China’s chemical inventory of existing chemical substances is IECSC, which stands for the Inventory of Existing Chemical Substances Produced or Imported in China (IECSC). There are two parts of IECSC, public part and classified/confidential part. Companies can check out the public part by themselves and shall only enquire Authorities for classified/confidential part. If substances are not listed in the public part, companies have to submit a formal enquiry to SCC to check whether a substance is listed in the confidential part. The enquiry costs 3000 RMB.
The Measures for the Environmental Management Registration of New Chemical Substances (MEE Order No.12) has entered into force since January 1, 2021. In accordance with its supporting document, the Guidelines for Environmental Management Registration of New Chemical Substances (hereinafter referred to as the “Guidelines”), polymers containing no more than 2% monomers or reactants of new chemical substances or belong to polymers of low concern can apply for records without quantity limitation if they are excluded in exemption circumstances.
The Ministry of Ecology and Environment (MEE) of the People’s Republic of China is consulting until September 14, on the proposal to add six substances to the country's existing chemical inventory. The MEE examines and verifies the application materials for adding chemical substances into the Inventory of Existing Chemical Substances in China (IECSC) in accordance with the Measures for Environmental Management Registration of New Chemical Substances (MEE Order 12) and the Guidelines for the Environmental Management and Registration of New Chemical Substances (hereinafter referred to as “Guidance”). The six chemical substances are have been found to meet the requirements of MEE Order 12 and the Guidance and will be added to the IECSC.
19 July 2022, China MEE announced that the 22 substances have fulfilled the requirements for IECSC supplementation and will be managed as existing chemical substances. CIRS warmly reminds that related enterprises must make sure whether their substances are existing substances. The Provisions on Environmental Administration of New Chemical Substances (MEE Order No. 12) require enterprises to complete new substance registration/record before manufacturing or importing, or they may face various punishments. To find whether the substance is existing substance, please search CIRS APCISS system.
In January 2022, the RCEP Agreement entered into force, covering 10 ASEAN countries, China, Japan, South Korea, Australia and New Zealand. After RCEP comes into effect, more than 90% of the trade of goods in the region will eventually achieve zero tariffs, which involves the chemical industry with more than 1,000 tariff numbers of RCEP origin rules, benefiting the import and export trade of chemicals. Within the RCEP coverage, most countries, including China, have adopted GHS classification and labelling systems, which requires the Safety Data Sheet (SDS) and labels of chemicals to comply with the GHS-related regulations and standards of each country and region.
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