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The draft inventory of Hazardous Chemicals of Priority Environmental Concern (HCPEC) is set to be released in a series of batches. The first batch of the “Hazardous Chemicals of Priority Environmental Concern” contains 142 chemical substances. Before being formally added to the draft version of the inventory the batches are first subject to a period of consultation. During March and April 2013, the first batch was passed to the enterprises operating within the chemical industry for consultation through the industry association. There is overlap between the 58 categories of chemicals highlighted in the MEP’s 12th FYP and the draft list. As stipulated in MEP order 22, “Measures for the Environmental Management of Hazardous Chemical Registration (Trial)”, the manufacturers and users of HCPECs are further required to conduct the environmental risk assessment and submit release & transfer report. Therefore, companies should be cautious about the inclusion of the List. For the new chemicals identified as “priority environmental concern”, companies just need to fulfill the risk mitigation obligations stipulated in the New Chemical Substance Notification (NCSN), which is beyond the scope of the Order 22.
On May 24 2013, the 4th national plenary session of Toxicology & Risk Assessment Committee under the Chinese Society of Toxicology was held in Suzhou China. During the discussion, experts from the CRC-MEP revealed that the first batch of the “Hazardous Chemicals of Priority Environmental Concern” (HCPEC), which contains 142 chemical substances. Prior to its release, the first batch had been subject to a consultation and review period during which relevant Chinese chemical companies analyzed and advised on various aspects of the new draft inventory. A large number of comments were collected from these companies and the MEP is now in its last round of assessment. It is estimated that the first batch of HCPEC list will come out later this year.
The “Measures for the Environmental Management of Hazardous Chemical Registration (Trial)” has attracted interest from many HC companies and environmentalists since its promulgation on October 10 2012. The obligations and requirements for HCPEC companies have received most attention. The new rules mandate that “the manufacturers and users of HCPECs should conduct environmental risk assessment on their HCPECs”, and that “the manufacturers and user of the HCPEs should fill in and submit the form of Release & Transfer report of HCPECs”. The “Release& Transfer Report” consists of the information on the emission, disposal, and recycling conditions of the HCPECs and the associated pollutants, as well as other computational data”. Disclosure of the information about the release and transfer information of HCPECs and the pollutants has been compared to the Pollutant Release and Transfer Register (PRTR) which is implemented in the developed countries, and thus enables China to make major progress in PRTR practice.
Though the MEP Order 22 has been implemented from March 1 2013, the HCPEC list has not been published yet. In fact, an internal memo regarding the first batch of HCPECs has been circulated by the MEP for comments. Totally 142 chemical substances have been included into the draft and the subject companies have been invited for consultation by mid-April.
A major issue for industry is the qualifying criteria for HCPECs. During the “Responsible Care Conference” in Beijing, which was held on April 24 2013 this topic was a major topic of discussion and inquiry. The selection criteria for HCPECs is not included in MEP order 22, however, chemicals that pose a high environmental risk, cumulative risk and health hazards (identified as carcinogen) are prime targets for selection during the identification of HCPECs. In addition chemicals with a high occurrence rate for environmental accident will also be considered, as revealed by the experts.
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12th Five-Year Plan on Environmental Risk Control of Chemicals
Although the HCPEC list has not been published yet, REACH24H hypothesizes that the HCPEC list will borrow heavily from the 58 categories of chemicals highlighted in the MEP’s 12th FYP. A prudent approach for companies wishing to get their ducks in a line before the release of the new inventory would be to carefully analyze the 58 categories chemicals in the FYP and cross-reference this list with their own chemical lists.
Under China’s New Chemical Substance Notification (NCSN), many chemicals have been identified as the chemical substance of high environmental concern, a major cause for alarm for the chemical industry. It is unclear whether the chemical substance of high environmental concern which is classified by the NCSN is subject to the MEP Order 22. CRC-MEP’s experts confirmed in Suzhou that the MEP Order 22 is applicable to the hazardous chemicals included in the “Catalogue of Hazardous Chemicals” (also known as the Chinese “C&L Inventory”) currently under management by the MEP Order 22. That is to say, only chemicals included in the Inventory of Existing Chemical Substances in China (IECSC) would be subject to Order 22. If the chemical substance was classified as the chemical substance of high environmental concern under the NCSN, companies would only need to comply with the risk mitigation required by the NCSN. Generally, inclusion of a chemical into the HCPEC lists should go through the specific procedures mandated under MEP22, that is to say companies will fulfill the obligations under the Order 22 as long as the chemicals are included in the HCPEC list.
