Taiwan’s new and existing chemical registration scheme entered into force at the end of 2014. After a careful review of the issues encountered after the first year of implementation, the major obstacle to smooth implementation is the Third Party Representative (TPR) system currently used. The good news is that Taiwan authority is considering implementing the OR concept in place of TPR to mitigate compliance burdens, according to Dr. Jowitt Li from Taiwan SAHTECH in ChemCon Europe 2016 held in Amsterdam, the Netherlands on 16 March.
The existence of Taiwan TPR enables full registration compliance and helps overseas manufacturers protect CBI. However unlike the OR model, Taiwan’s TPR only works for domestic importers and manufacturers and overseas companies are not able to obtain registration certificates using TPR.
For instance, in cases where there are CBI concerns, and an overseas manufacturers uses multiple Taiwanese importers, it will require each importer to designate a TPR (the TPR could be the same) and communicate with the overseas manufacturer to register substances. According to Anna Hitschler from BASF, management of complex supply chains remains a challenge with the existing TPR model and implementation of the OR model will foster efficiency in chemical registration.
The registration scheme used for new and existing chemicals is relatively new to Taiwan. Although the OR concept is adopted in EU, South Korea, China, etc., when Taiwan’s authority outlined their registration scheme OR was not used. Taiwan’s authority formulated such a system in order to strictly regulate the behavior of Taiwanese manufacturer and importers. However, the reality hasn’t matched expectations. Some importers refuse TPR designation obligations citing that they cannot register without full disclosure of product information from the overseas manufacturers. In this case, overseas manufacturers will have to take responsible for all registration issues, e.g. choosing a TPR they trust, paying the registration fee and requesting the notarized official appointment document between TPR and Taiwan importer, etc. However, after all these efforts have been made, the registration certificate still belongs to a Taiwanese importer.
As we known, Ms. Tsai Ing-wen was elected Taiwan’s new leader and will take the oath of office on 20 May. Her Democratic Progressive Party (DPP) will control Taiwan’s legislature and give her broad authority to enact her policies in office. During the administration of the Nationalist Party, DPP as the opposition party contributed to development of a strict and complicated chemical registration scheme in Taiwan without adopting the common OR concept. After becoming the governing party, the new government will be in charge of issues concerning economics. An overly strict regulation could also possibly limit economic development in Taiwan and implementing the OR system would also align Taiwan with international best practices. The TPR system will therefore probably be reconsidered and according to Dr. Li some inter-ministerial discussions are already being conducted.
Separate regulations to govern chemical registration are used namely Taiwan’s TCSCA and OSHA. Coordinated effort is needed between Taiwan EPA and Taiwan MoL in revising regulations to facilitate a better registration scheme. Before any substantial progress is made, the current scheme should still be followed.
