On August 26, 2022, the Chinese Ministry of Ecology and Environment (MEE) issued a notice1 to make public 2,404 new chemical substance record notifications that were received in the first half of 2022, covering more than 7,900 new chemical substances. The attached list contains the applicant and the corresponding representative agent (if have), the time for record notification, the receipt number, and the number of new chemical substances. Details can be accessed here2.
One and a half years have passed since the Measures for the Environmental Management Registration of New Chemical Substances (MEE Order No.123) took effect in China on January 1, 2021. This regulation thoroughly modified the previous notification types of new chemical substances into regular registration, simplified registration and record notification. New chemical substances manufactured or imported in quantities below 1 ton per year, polymers containing less than 2% of a new chemical monomer/reactant or PLCs are subject to record notification.
Notably, there is no approval for record notification, which means that businesses can start relevant activities immediately after submitting application materials and receiving the receipt sent via the online registration system. The MEE will only conduct spot checks of the materials.
However, in practice, it doesn’t mean that obligations under record notification are that easy to fulfill. An official from the MEE-SCC, shared on the virtual forum held in July 2022 that quite a lot of problems have been identified in the spot check of record notifications, most of which were for polymers (CL news). The applicants in question will be asked to provide materials for supplementary or correction. If applicants fail in providing the required materials within the limited period, the record notification receipts will be revoked, and the corresponding activities will be ordered to cease.