On Dec 9th, 2019, China’s Solid Waste and Chemicals Management Center (SCC under the Ministry of Ecology and Environment) issued a notice[1] reminding simplified and regular notification certificate holders to submit annual reports for their production and import activities of new chemical substances in 2019. The online submission system[2] will open on Jan 1st, 2020 and the submission will be due by Feb 1st, 2020.
Annual reporting of notified new chemical substances is a basic post-notification requirement in China. According to Article 36 of the Measures for the Environmental Management of New Chemical Substances[3] (MEP Order 7), certificate holders of regular notifications (hazardous new chemical substance and hazardous new chemical substances of priority environmental concern) and all simplified notifications are obliged to submit an annual report to the SCC-MEP by February 1st every year.
However, according to the draft revision of MEP Order 7[4] issued in July of 2019, the deadline for submitting annual report will be changed from Feb 1st to Apr 30th in the future. The scope of annual reporting will be limited to new chemical substances for regular registration which are stipulated on the registration certificate as needing annual reporting. The draft is still under internal deliberation and the possible time for the release of the final version is expected by October of 2020. Thus, this time the submission is unaffected.
Before the deadline, certificate holders are allowed to revise or supplement the submitted annual report. Certificate holders failing to submit the annual report can be fined up to RMB 10,000.
