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Taiwan implemented the revised edition of Toxic Chemical Substance Control Act

Original Article from CIRS

On 11 December 2014, Taiwan officially implemented the revised edition of Toxic Chemical Substance Control Act (TCSCA). On 22 November 2013, the revised edition of TCSCA was passed by Taiwan Legislative Yuan, and was published on 11 December 2013 by Taiwan Presidential Decree.

The revised TCSCA has the similar mode as EU REACH, which requires the manufacturers or importers to complete the existing chemical substance (with a certain annual tonnage) registration within the required time period; the manufacturers or importers to complete the new chemical substance registration before manufacturing or importing. According to the annual tonnage of manufactured or imported new chemical substances, the registration types can be classified as standard registration, simple registration and small amount registration. Manufacturers or importers can complete the registration obligation by appointing domestic agencies.

On 5 December 2014, Environmental Protection Agency (EPA) published the New and Existing Chemical Substance Registration Rules before implementing the revised TCSCA. Enterprises are advised to pay attention to the following contents:

  • Existing chemical substance registration: manufacturers or importers with average annually tonnage larger than 100 kg for 3 years before registration shall complete the first stage registration for existing chemical substance during 1 September 2015 to 31 March 2016. After finishing the first stage registration, Taiwan competent authorities will publish the list of existing chemical substances that need registration and the registration deadline. The buffering period measures for new chemical substance are also included in the registration rules.
  • Buffering period measures for new chemical substance: the new chemicals manufactured or imported during 11 December 2014 to 31 December 2015 can apply for the registration file according to small amount registration. The registration file can be used for one year. Manufacturers or importers can manufacture or import the new chemicals during the valid period of the registration file, and meanwhile preparing for the new chemical substance registration.
  • The third supplementary list of existing chemical substance: manufactures or importers that want to manufacture or import unlisted existing chemicals have to submit related certificate files before 31 March 2015. After verification, the unlisted existing chemicals can be managed as existing chemicals without the requirement for new chemical substance registration.

Taiwan is one of the biggest areas with chemical trade. With the implementation of this act, significant impact will be drawn on the global chemical industries. Before the implementation of the act, TCSCA only regulated the toxic chemical substance without the relevant management of new chemical substances. In order to improve the chemical substance regulation situation in Taiwan, Ministry of Economic Affairs MOEA has started to build a suitable chemical regulation in Taiwan area since 2007. On 2 November 2009, Taiwan Labor Committee published existing substance registration instructions, and built the first draft of Taiwan existing substance list. The first list addition happened during June to August 2012 and the second list addition, which was the final version of TCSCA, happened during June to July 2014, which is now the base for all the chemical substance registration. The revised TCSCA is planning to build a Taiwan chemical substance database to filter and assess toxic chemical substances. Moreover, the revised TCSCA has also strengthened the administration of the forth class of toxic chemical substance. Manufacturers or importers have to obtain the verification documents before any manufacture or importation activities.

Even though Taiwan TCSCA uses the similar mode as EU REACH in administration of chemical substance, many differences can still be found between them, on which enterprises should pay their attention . After the implementation of TCSCA, the new situation can be both opportunities and challenges for enterprises. As opportunities, enterprises now can do the business in a much healthier Taiwan chemical market, in which only the registered chemicals can have trade activities; as challenges, however, as high as 2,000,000 TWD will be fined for the enterprises that do not comply with the regulations. It is advised that enterprises constantly pay attention to the regulation changes, and do the best to prepare for the new implemented rules.

CIRS provides a series of tailored chemical regulation compliance services in Asia-Pacific area. Should you have any question, please do not hesitate to contact us.

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