On Oct 19, China’s Ministry of Environmental Protection (MEP) released the Measures for the Environmental Management Registration of Hazardous Chemicals (Revision for Public Consultation) and it’s supporting documents. The regulation stipulates the environmental management registration requirements for Hazardous Chemicals (HC), as well as the pollutant release and transfer register (PRTR) program and environmental risk assessment of Hazardous Chemicals of Priority Environmental Concern (HCPEC).
Measures for the Environmental Management Registration of Hazardous Chemicals (MEP Order 22) was first issued in 2012 and the trial run started on Mar 1, 2013. However, the implementation was impeded as the regulatory scope could not be defined without two essential chemical lists which were later published on:
Apr 4, 2014 – Catalogue of Hazardous Chemicals of Priority Environmental Concern
Feb 27, 2015 – Inventory of Hazardous Chemicals
Compounding this issue was the complicated and highly technical requirements and high costs associated with environmental registration as articulated within the regulation which made industry extremely unreceptive. In consideration of this and in light of State Council’s requirement to further streamlinine administration, the following significant changes are made in the draft revision of MEP Order 22:
HC import & export is no longer regulated under this regulation.
Enterprises subject to the environmental management registration scheme are clarified to be manufacturers and users of
Any HCPEC ≥100 kg/yr
Any HC (excluding HCPEC) ≥1 ton/yr
* Using active ingredients or the primary active ingredients in pesticide formulations is exempted
Registration certificates will not be issued any more. Instead, the list of successful registrants will be regularly published by environmental protection administrations at provincial level.
Any new enterprise falling under the scope of this regulation should finish registration within 6 months from commencement of commercial operations. Reconstruction or expansion will not require new registration, although new environmental risk assessment report shall be submitted during annual reporting and record filing.
Forms and other documents required for registration and annual reporting are much more simplified. Environmental risk assessment report doesn’t have to be compiled by accredited institutions.
Industry’s obligation to self-disclose environmental management information of hazardous chemicals is emphasized.
Detailed comparison and analysis will be given during the Chemical Regulatory Affairs Conference (CRAC) 2015 to be held on Nov 2 & 3 in Hangzhou, China. (see CL news: China MEP Order 22 Set for Further Amendments)
Opinions can be submitted via chem@mep.gov.cn before Nov 30.
