Updates on New Chemical Substance Notification in China from MEP-SCC during ChemCon 2015
original article from CIRS
Mr. Ethan Zheng, Regulatory Consultant and BD Manager from CIRS, has attended ChemCon 2015 in Hong Kong. During the conference, Mr. Xiaojian Liu, from MEP-SCC, was invited to give a talk on the topic of “Implementation, Development and Guidance Documents for the New Chemical Substance Notification in China”.
The following contents are the first-hand information regarding to the new chemical substance notification in China compiled by CIRS.
The revision work for the Guidance for New Chemical Substance Notification and Registration has started since early 2014. It is a very important document for the management of new chemical substance in China. The currently used guidance is the version that came into effect on October 15, 2010, which is a very old one. The content includes application scope, notification types and procedures, document requirements, polymer provisions, post-registration management, etc. However, some defects and problems have been found in the old version, so, MEP-SCC decided to revise the guidance from January 2014.
Revision Principles
- Guidance framework will not be changed. Works will be done majorly on supplementation, completion, clarification and modification of relevant problems.
- Both regulations of oversea countries and the real situation in China will be considered simultaneously.
- Expert comments, governmental requirements and industry advices will be taken into consideration to make the final decision.
- Related provisions of MEP Order 7 shall be complied.
Main Changes in the Revision Draft
1. Management Policy Revision
Revised Item |
Current Guidance |
Revised Draft Guidance |
Qualification of domestic notifier |
Business bodies registered in China with legal personality |
Business bodies registered in China (no requirement for legal personality) |
Definition of holder of registration certificate |
The domestic notifier is the registration certificate holder; the local representative agent is the registration certificate holder for foreign notifier |
Either the domestic notifier or the foreign notifier will be the registration certificate holder |
Qualification of local representative agent |
1.Pass the annual inspection |
1. Requirement 1 and 3 are deleted. |
Scope of application territories |
China; the Bonded and Export Processing Zone |
China; the Bonded and Export Processing Zone; China Pilot Free Trade Zones |
Notification Way |
With specific tonnage quantity |
Applicant can choose to notify with specific tonnage quantity or tonnage level (level 4 is required for specific tonnage) |
Publicity and announcement of registration information |
Registered substance name, notifier, notification type, new chemical substance management category |
The hazard classification of “Key Hazardous New Chemical Substance for Environmental Management” shall also be included |
Submission of notification dossiers |
Complete set of dossiers shall be mailed or delivered in person |
Complete set of dossiers can be submitted via notification software issued by MEP-SCC. Paperless notification is planned to be launched in the future. |
Simplified notification for polymers |
None |
Special situation of simplified notification does not apply to unstable, degradable or water-absorbing polymers |
Modification of information on registration certificate |
The registration certificate holder shall submit application |
If the registration certificate is a foreign company, both the holder and local representative agent shall submit the application jointly.. |
2. Data Requirement Revision
Revised Item |
Current Guidance |
Revised Draft Guidance |
Test report validity |
None |
1.Test report conducted in China shall be completed within the validity of their qualifications in the test report issued |
Test method |
The first version of The Guidelines For The Testing Of Chemicals |
The latest version of The Guidelines for the Testing of Chemicals, which was published in 2013 |
Chinese test organism |
Organisms cultivated and bred in China, including Gobiocypris rarus (Rare minnow), Xiphophorus helleri (Sward-tail fish), Brachydanio rerio or Daniorerio (Zebra Fish), activated sludge etc. |
Local organisms cultivated and bred in China, especially Gobiocypris rarus (Rare minnow), activated sludge etc. |
Data requirement and data waiving |
None |
…… |
Risk Assessment Report Requirement |
Safety rules for classification, precautionary labeling and precautionary statements of chemicals (GB 2006 series) |
|
3. Addition of Annexes
Revised Item |
Current Guidance |
Revised Draft Guidance |
Notified Use |
Notifier completes with actual situation |
Use code list of chemicals is provided as annex |
Post-registration report |
None |
Report format has been redesigned and added as annexes in the guidance |
4. Simplification of the Management Procedures
Revised Item |
Current Guidance |
Revised Draft Guidance |
Modification of information on registration certificate |
If modification is approved, the old registration certificate shall be changed for a new one |
Modification receipt will be issued by MEP-SCC, the old registration certificate does not need to be changed |
New Chemical Substance for Each Activity Report |
No minimum limit of the transfer |
If the transfer amount of Key Hazardous New Chemical Substance for Environmental Management is more than 10 kg, the New Chemical Substance for Each Activity Report is required |
Simplified notification of polymers |
Registration tonnage is limited and will be present on the registration certificate |
There is no tonnage limits, and registration tonnage will not be listed on the registration certificate |
Next Step on Guidance Revision
Public comments will be collected and reviewed by expert committee and management authorities. Training programs will be carried out by MEP after officially publication of the guidance.
CIRS Advice
- Enterprises are recommended to choose experienced representative agent to assist them to finish the notification, in order to save time and reduce cost;
- For those who have not started the testing projects, it is recommended to get prepared in advance according to the latest requirement;
- It is recommended that enterprises study the updates or work with their representative agents to make a better business strategy.
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