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Whether new chemical substances used in their various downstream applications (cosmetic ingredients, pesticide ingredients and active pharmaceutical ingredients (APIs) ) are subject to China new chemical substance notification (China NCSN, a.k.a China REACH) is a subject which has been debated ever since the implementation of the Measures for the Environmental Management of New Chemical Substances (MEP Order 7).
In order to clarify some uncertainties which this issue has drawn attention to, the FAQs section on the CRC website was recently updated. 23 questions were added on 23 Oct 2013. In this latest update Q129-Q133 clarified that:
If a new chemical substance is used as a cosmetic ingredient it is subject to China NCSN, irrespective of whether it also undergoes new cosmetic ingredients registration.
Similarly new chemical substances used as pesticide ingredients or intermediates are also subject to China NCSN, irrespective of whether it also undergoes pesticide registration.
All new chemical substance used as API are subject to China NCSN
Additionally all new chemical substances used as raw materials and intermediates in the production of veterinary medicine, food additives, feed additives etc., should also comply with the China NCSN.
The important exceptions to this rule are for imported finished products with chemicals not listed in the IECSC, the ingredient(s) of which would individually be classified as new chemicals under MEP Order 7. These finished products are only subject to category specific registration, e.g. cosmetic registration, pesticide registration etc. and are not required to undergo China NCSN.
