1. Background
Recently, REACH24H China NCSN group received a technical comment from the Expert Committee about one Simplified Notification project (general case), of which REACH24H helped to submit the dossier. The comment goes that "According to the existing data, the new chemical will be identified as Hazardous of Priority Environmental Concern; therefore the Risk Management Measures should be supplemented in the dossier, as well as the estimated concentrations of the notified chemical in the environment". However, the term "Hazardous of Priority Environmental Concern" is most frequently related to the regular notification announcement or the official publication on the registration status of regular notification case, nevertheless this time it was included in the expert comment of this simplified notification case. The natural question pops out: "Will chemicals notified through simplified notification also be identified as Hazardous of Priority Environmental Concern?" Some detailed interpretation might be necessary to clarify the confusion.
