China 'REACH' to be Expanded

China's Ministry of Environmental Protection (MEP) held an internal "consultation" during May/June 2009 on expanding PEANCS, China's existing regulation of New Chemical Substances (which became effective in 2003). The current draft under consideration has not been published, so much is still speculative, but the proposed changes are slated to become effective  October 15, 2010.

Provisions already contained in the EXISTING REGULATIONS:

A Notification Form must be submitted and a Registration Certificate received prior to the manufacture/import of a new chemical substance in China.

Only "new" chemicals are covered. Chemicals listed on the Inventory of Existing Chemical Substances manufactured or imported in China (IECSC) do not need to be notified/registered. Currently, the notification/ registration/reporting period lasts only until the new chemical has been evaluated by the State Environmental Protection Administration (SEPA)  and published to the IECSC. 

Eco-toxicological testing in China with Chinese organisms must be submitted with the Notification Form.

Proposed NEW REGULATIONS:

Only domestic Chinese companies may submit a Notification Form (wording in current draft is somewhat unclear).

Data requirements increase for notifications of quantities over 1 tonne per year: more detailed test data for physico-chemical properties, toxicity and eco-toxicity; more detailed environmental risk assessment report; new requirements for classification & labeling information and a safety data sheet.

Increasing data requirements for quantity bands: 1-10 tonnes, 10-100 tonnes, 100-1000 tonnes, over 1000 tonnes

Chemical substances will receive one of three classifications: "general", "hazardous", or "of environmental concern". Appropriate risk control measures will be required for substances of environmental concern.

Increased risk management obligations for registrants, the supply chain and end-users, including hazard and exposure measures for labeling, packaging, transportation and disposal.

This summary is intended to give you an easy-to-understand overview and does not constitute legal advice. The actual standard in the original language should be reviewed and used for all business, legal, and product compliance purposes.

Should you need assistance in assessing how China's REACH will affect your company, we stand ready to help you. Just email us or give us a call at 972-679-8996 for a timely and personalized response.

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