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Inclusion of China New Chemical Substance into IECSC is Pending

It is known that new chemical substances notified under the China New Chemical Substance Notification (China NCSN) will have a chance of being included in the IECSC. Even though some pioneer companies are already qualified to have their substances included into the IECSC, the practical listing work is pending.

Stipulated in the MEP notice 123 of 2010, the China NCSN certificate obtained under the MEP Order 17 can be valid until the notified new chemical substance is added into the IECSC. The certificate holder applying for the inclusion of the substance into the IECSC is required to submit the actual activity report to the CRC-MEP within one month after the 5th year since the first date of actual manufacturing or import activity.

However, the relevant procedures are still being formulated for adding the new chemical substances notified under the MEP Order 17 into the IECSC. When the registered substance gets listed into the IECSC, it would be exempted from necessary surveillance since in China there’s no management over all the general existing chemical substances.

Currently, apart from the absence of management over all the existing chemical substances, China lacks punitive measures for companies manufacturing/importing new chemical substances without notification. The local environmental protection agency could only conduct supervision over notified new chemical substances, while leaving the un-notified chemical substances unattended. Although the MEP is to start a national environmental impact investigation on the chemical production next year, it is still a tough task to locate all the new chemical substances un-notified, let alone sound measures to penalize or crack down the illegal activities concerning the new chemical substance un-notified.

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