China and EU Chemical Regulation Forum Q&A Summary


14 March 2018, the China and EU Chemical Regulations Forum was successfully held in Shanghai. This Forum mainly focuses on the latest chemical regulations in EU and China. Officials from ECHA, Shanghai Entry-Exit Inspection and Quarantine Bureau and Shanghai Administration of Work Safety as well as experts from CIRS spoke during the Forum.

Following are some of the questions raised during the Forum and their answers:

Q1: When do we need to conduct pre-marketing record for the import of paintings?

A: Record is voluntary. If the importer frequently imports one same product within a year or within a period of time, then record is suggested. But if the product is just imported for one time or occasionally, then record is not suggested. Enterprises can accept sampling inspection at the port if their products are imported occasionally.

Q2: How to define low-risk hazardous chemicals?

A: Low-risk hazardous chemicals will be determined by experts from Shanghai CIQ through evaluations. These experts will judge whether the products can be cleared quickly based on the quantity and property of the products. Enterprises shall make it clear that the evaluation is dynamic. Products that were judged as low-risk hazardous chemicals may also be considered as high-risk hazardous chemicals in future evaluations.

Q3: Can you please tell us the time cycle and term of validity of the hazardous chemical registration done by the same importer?

A: Time cycle: 15 working days;

Term of validity: 3 years.

Q4: Do we need to use the name in the customs code directory when preparing the SDS and labels of our products?

A: As far as we know, even if the commercial name of the products on SDS and labels are different from the name on the customs code directory, the products can still be cleared by the customs.

Q5: Will the SDS, labels as well as test reports issued by qualified laboratories lose validity?

A: Enterprises are suggested to update the SDS and labels every two years. This is because the shipping rules will be updated every two years and the air transportation rules will also be updated regularly. The test reports will lose the validity as well. Enterprises are responsible for informing related departments of the newly-discovered hazards of the products.  

Q6: Do we still need to complete hazardous chemical registration if we have acquired the classification verification report of the hazardous chemical as well as the label verification certificate? Do we need to register again if we need to import the same hazardous chemicals from different manufactures?  

A: Registration is required as well. Enterprises need to complete the hazardous chemical registration when they manufacture or import the hazardous chemicals for the first time. But the same substance will only be registered once. If the substance was imported from different manufactures, the importer needs to provide the technical documents provided by the manufactures as well.

Q7: Does the "Double-100" policy cover imported chemicals worldwide or only target imported chemicals in Shanghai?

A: It is for imported hazardous chemicals in China which are listed in the Catalogue of Hazardous Chemicals 2015.

Q8: Will the Customs clear our products directly if we acquired the label verification certificate?

A: The Customs may still need to confirm whether the verification report corresponds to your products. Besides, if results of the test report and verification certificate are inconsistent, the test report issued by laboratories will take precedence. But the verification certificate will to some extent reduce on-site verification projects. 

Q9: Classifications of US GHS and China GHS are different. Will this affect the customs clearance in China?

A: The Customs will not check the English labels. Enterprises are suggested to rip the English labels off before the customs clearance.

Q10: SDS and labels require part of the hazardous components while the Customs requires all the components of the products. Is there any possibility that the two criterions can be unified?

A: What is more important is that enterprises are not allowed to conceal the hazardous characteristics of their products on the grounds of the protection of their business confidentialities.

Q11: Two years ago, we submitted the application for inclusion into the IECSC after the new chemical substance typical notification was completed. But we have not received any message yet. Why?

A: MEPSCC does not explain how long it will take to include a substance into IECSC. But MEPSCC have already notified all the enterprises that need to submit supplementary materials. If you do not need to supplement materials, maybe you will receive feedbacks from MEPSCC soon.  

Q12: Can we submit the applications for inclusion into IECSC by ourselves? After our substances are included into IECSC, how will we be affected?  

A: Enterprises can submit the applications for inclusion into IECSC by themselves. After the substances are included into IECSC, these substances will be managed as existing substances. Enterprises do not need to submit the annual report for the substance any more. The manufacture and import of these substances will not be limited as well. But at the same time, their rivals can also import/manufacture the substance without any limitations in volumes.

Q13: What are the difference between new chemical substance typical notification and simplified notification?

A: 1. There are two types of simplified notification:

a) Simplified notification specific condition:

  • For intermediate use with tonnage under 1ton per year;
  • For export only with tonnage under 1 ton per year;
  • For scientific research with tonnage between 0.1 to 1 ton per year;
  • For polymers containing less than 2% new chemical substance weight by weight;
  • For polymers of low concern;
  • For PPORD , under 10 ton per year and less than 2 years;

b) Simplified notification basic condition:

  • For general purpose of new chemical substances with tonnage under 1 ton per year;

2. Typical notification:

  • For general purpose of new chemical substances with tonnage over 1 ton per year

Q14: When applying for REACH inquiry, can we submit the spectrum results by ourselves? 

A: Yes, spectrum analysis can be done by enterprises if enterprises are able to fulfil relevant requirements under REACH.

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