The CRC-MEP has updated on 8 Nov 2012 the FAQs concerning the China New Chemical Substance Notification(NCSN), which includes 103 the most-frequently-asked questions submitted by notifiers to the Chemical Registration Center of the Ministry of Environmental Protection in China (CRC-MEP) with additional 14 questions appended to the previous version.
Although stipulated in the Guidance Document (2010), as for the serial notification, the minimum data requirements can be met by grouping the testing data of one or more of the serial substances, there has been some believes that at least a complete set of data of toxicological and eco-toxicological testing of one substance in the series should be submitted. In the updated FAQs, Q.92 has clarified that the physic-chemical data are needed for all the serial substances, while for the toxicological and eco-toxicological data the CRC accepts data combined by testing data of more than one substances in this series. This clarification might relieve the notifiers since the CRC-MEP allows more flexibility on data requirements of serial notification.
Although notifiers were familar with the concept of tonnage accumulation for joint and serial notification, most notifiers do not know that this principle also applies to repeat notification when the same testing reports from the previous notifiers are used. It should be emphasized that even if only one same testing report is found to be used, the tonnage accumulation will occur.
In another case, if the same testing report used is gained from the successful notification under the MEP Order 17 (the old version for the China NCSN, now replaced by the MEP Order 7), the post-notifier do not need to notify the same chemical substance under repeat notification and therefore no tonnage accumulation will occur.
The full PDF version in English of FAQs including Q1 to Q82 is available. If you want to have the newest version please contact us. Any feedback concerning the China NCSN is welcome and we’ll collect and submit them to the CRC-MEP.
