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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 Inventory of Existing Chemical Substances in China (current version IECSC 2013). With more and more qualified new chemical substances waiting to be listed into IECSC, the Solid Waste and Chemicals Management Center (SCC) under China MEE has streamlined IECSC inclusion.
Applicable scope
The IECSC inclusion procedures applies to
new chemical substances that finished general notification under SEPA Order 17 (known as the 2003 version of Measures for the Environmental Management of New Chemical Substances, now replaced by MEP Order 7 in 2010)
new chemical substances finished regular notification under MEP Order 7
So far 3 batches of 104 substances have been listed into IECSC 2013, including:
31 substances listed on Mar 10th, 2016 (all notified under SEPA Order 17)
45 substances listed on Nov 21st, 2018 (43 substances notified under SEPA Order 17 and 2 substances notified under MEP Order 7)
28 substances listed on Jan 11th, 2019 (19 substances notified under SEPA Order 17 and 9 substances notified under MEP Order 7)
When to apply for IECSC inclusion?
Stipulated in the MEP notice 123 of 2010, the certificate obtained under the SEPA Order 17 is valid until the notified new chemical substance is added into the IECSC. The certificate holder can apply for the inclusion of the substance into the IECSC within one month after the 5th year of the first date of actual manufacture or import.
For new substances that finished the regular notification under MEP Order 7, according to the classification of administrative management:
For “general” new substances, they will be automatically listed after five years from the first date of actual manufacture or import
For the “Hazardous” new chemical substances (including those of “Priority Environmental Concern”), applicants can apply for inclusion within six months before the five-year deadline of the first date of actual manufacture or import
What materials are required for IECSC inclusion?
The qualified original notifiers can prepare relevant materials according to the IECSC inclusion procedures and hand in the application form (see below) for IECSC inclusion.
In addition to the application form, below are the attachments that require submission.
Power of Attorney (if need)
Copy of registration certificate
Proof of the first activity
Report of the actual activities
Application of confidentiality of identification info (Only the information has been confidential on the registration certificate can be applied for confidential supplementation)
Update of identification info (if needed)
Hazard classification & Administrative management category
Statement of risk control (whether has pollution event)
Others (update of registration holder, etc.)
The actual activities report is a demanding part of the application process, which should be compiled in compliance with the China NCSN Guidance Document (2010), detailing the manufacture, transfer, release, exposure, waste management of new chemical substances during this period, implementation of risk control measures and administrative requirements, supervision and inspection by the authority, environmental impact around the factory manufacturing/processing/using the new chemical substances. For hazardous new chemical substances of priority environmental concern, the outcomes of a report on environmental monitoring or evaluation should also be provided.
Future changes
China’s MEE published on Jul 9th the draft revision of the MEP Order 7 (CL news). As proposed, for listing registered new chemicals into the IECSC, the qualified substance will be listed into the IECSC after 5 years from the first date of registration by the MEE.
For transitional measures, when the draft revision comes into force, the eligible new chemical substances notified under MEP Order 7 will be added into the IECSC by the MEE five years after the first-time activity or five years after the implementation of the draft revision. Eligible new chemical substances notified under SEPA Order 17 will be added into the IECSC 6 months after the implementation of the draft revision. There will be no need to carry out a revaluation on the substance by the evaluation committee.
