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The question whether the short-term toxicity to earthworm test has to be conducted in China received ambiguous answers. Recently, officials from Chemical Registration Center of Ministry of Environmental Protection (CRC-MEP) clarified this question.
If the short-term toxicity to earthworm test data is required to meet the minimum data requirements, the question could be answered as follows,
In case of the testing data unavailable from overseas accredited labs at the time of submission, the notifier will be requested to conduct the test in Chinese territory.
In case of available testing data obtained from overseas accredited labs, the notifier is allowed to submit the data in the notification dossier, instead of conducting additional test in China.
Besides, one should also understand that the CRC-MEP sticks to the principle that once submitted to the authority, the notifier acknowledges that what is included in the dossier is all that is available. Therefore, if the notifier fails to include the short-term toxicity to earthworm testing data when submitting the notification dossier, they will be asked to conduct the test in China even if they do own the testing data generated from the MEP-accepted overseas labs. As an extrapolation from this case, the notifiers should submit as much available information as possible in their notification dossier, which is compliant with the original intention of CRC-MEP to promote complete submission of materials at the first time.
