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Non-CN manufacturers can not submit new substance notification on their own under China REACh

  •   25 Jan 2011
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    Compared with the previous version of Measures on the Environmental Management of New Chemical Substances, one of the significant changes is only China-based companies can notify directly. For Non-CN manufacturers, they can only submit the notification by their Chinese affiliate or appointing an “Only Representative” in China.

    Under the previous edition of "Measures", there are three types of notifiers:

    · The domestic manufacturer;
    · The domestic importer;
    · The overseas trader which plan to export the new chemical substances(Including Hong Kong Special Administrative Region, Macau Special Administrative Region Separate Customs Territory of Taiwan, Penghu, Kinmen, and Matsu, TPKM);
    That means non-CN manufacturers can notify the new substance directly under the previous edition of "Measures".

    The revised "Measures" classified the notifiers also as three types, which are domestic notifier, overseas notifier and the agent ("only representative"). The overseas notifier is required to assign an "only representative" to deal with notification on behalf of him. In other words, the overseas notifiers are not authorized to directly notify under China REACh.

    In addition, according to the new guidance of China REACh (draft), the final certificate holder should not be the overseas notifier itself but the "only representative". The name of the overseas notifier will be listed on the register certificate issued by CRC. In case of this, the only representative shall take on all the responsibilities and obligations. Meanwhile, the overseas notifiers are in duty bound to timely provide to the only representative all the required information and support. Whereas, the only representative is responsible to keep business and technical information confidential with respect to the requirements of the overseas notifiers.

    For Non-CN manufacturers, without an affiliate in China, they can only submit the notification by appointing an "Only Representative" in China. For these overseas notifier, we kindly draw your attention that "only representative" play a crucial role in the notification process.

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