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China MEP Order 22: Gap between Set Goals and Implementation Status Quo

  •   25 Jul 2014
  •    Jane Zhou
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    China Hazardous Chemical ManagementMeasures for the Environmental Management Registration of Hazardous Chemicals (Trial) (a.k.a. MEP Order 22) came into force from Mar 1st, 2013, with the goal of improving China’s environmental management of hazardous chemicals.

    Since MEP Order 22 has not yet been put into full scale implementation, many enterprises are uncertain how they will be affected, what they should do to comply with the regulation and what they should do to get fully prepared. This article introduces the progress of enforcement and development of the management system under MEP Order 22.


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    The article defines that HCPEC manufacturers/users are specifically required to conduct environmental risk assessment by outsourcing it to accredited third parties. Should these accredited parties performing specific tests according to internationally recognized standards (e.g. GLP, ISO 17025, etc.) or are they obliged to follow Chinese standards to make this assessment?
    Thursday, 14 August 2014
    Dear Hedwig, Since HCPEC are nominated from existing chemicals and their hazards are relatively well-recognized, tests are barely necessary and the hazard data can be cited from authoritative data sources. The hazard indexes/indicators, data usage, decision logic and test requirements should be as specified in the Guidelines for Risk Assessment of Chemicals (a draft HJ standard). Data from GLP studies are recommended to increase the data reliability and reduce deviations, but not compulsory (not written in the Guidelines). Best regards, Jane Zhou
    Thursday, 14 August 2014