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At the 15th Chemical Regulatory Annual Conference (CRAC) held by REACH24H on November 17, 2023, Mr. Chen Jinhe from the National Registration Center for Chemicals (NRCC) of the MEM and Mr. Yu Xin from Shanghai Emergency Management Affairs and Chemical Registration Center introduced the regulatory status of Hazchem registration in China, with a focus on further indicating the Hazchem registration requirements.
In 2012, the Measures for the Administration of Hazardous Chemicals Registration (SAWS Order No. 53) was developed in accordance with the Regulation on the Control over Safety of Hazardous Chemicals (Decree 591). According to Article 2 of the SAWS Order No. 53, manufacturers and importers of Hazchem listed in the Inventory of Hazardous Chemicals are obliged to complete the Hazchem registration and obtain the registration certificate. Although the SAWS Order No. 53 has not yet been revised in this regard, the scope of enterprises subject to Hazchem registration has been expanded in practice, pointed out by Mr. Chen. With the launch of the Hazardous Chemical Registration Comprehensive Service System in early 2022, in addition to Hazchem manufacturers and importers, more enterprises are required to report the Hazchem information via this system, including:
Hazchem operators that have obtained the Hazchem Operation License;
Hazchem users that have obtained the Hazchem Safe Use License;
Chemical enterprises (without Hazchem Safe Use License) and pharmaceutical enterprises that are classified into the category of “Manufacture (25 ~ 28)” according to GB/T 4754 Industrial classification for national economic activities; and
Certain enterprises that are designated by the local authorities.
To enable the smooth roll-out of the Hazchem QR code policy, compliance with the Hazchem registration via this national system is a necessary step, since the QR code cannot be generated if the registration information is incomplete. Many pilot provinces and cities issued documents in 2022 to require relevant enterprises to complete the registration information supplementation. Currently, this national system only allows manufacturers or importers obliged to complete Hazchem registration to generate QR code online automatically. For the abovementioned four types of enterprises, they are only required to report simplified information on the new platform and are not able to obtain the Hazchem registration certificate, thus no QR code will be assigned to them. Moreover, their submitted data will only be reviewed by the local management department at district/county/city level and the provincial registration office, NRCC will not be involved in the review work. There is a plan to revise SAWS Order No. 53 to consolidate the experience of recent years. However, the revision will not come out very soon.
In May 2023, the MEM released the 2023 work plan for the special inspection on safety management of 35 hazardous chemicals (Hazchem) throughout their manufacture, import, operation and use, focusing on the implementation status of obligations including Hazchem registration, labeling, SDS, and hazard identification and classification, etc. According to Mr. Chen, led by the NRCC-MEM, local departments conducted the first special on-site inspection of 2023 on the safety management of target 35 Hazchem. About 2,000 enterprises were inspected, including 996 Hazchem manufacturers, 37 Hazchem importers, 403 Hazchem operators, and 378 Hazchem users. 888 of these inspected enterprises, were found in violations. Major violations are:
Failing to complete the Hazchem registration, and lacking file management;
Failing to provide compliant SDS and label, and lacking hazards communication;
Failing to display warning signs in the workplaces, and lacking on-site safety management.
“The MEM is considering regularizing on-site inspections in the future”, said Mr. Chen. In terms of the inspection objects, not only the registered enterprises will be inspected. Enterprises that may be involved in Hazchem will be subject to on-site inspection, whether they have registered via the Hazardous Chemical Registration Comprehensive Service System or not.
At the conference, Mr. Yu Xin shared the statistics of inspections conducted in Shanghai. A total of 240 enterprises were inspected on-site or spot-checked online, including 113 Hazchem manufacturers, 37 Hazchem importers, 91 Hazchem operators, 8 Hazchem users (with Hazchem Safe Use License), 11 chemical enterprises (without Hazchem Safe Use License), 15pharmaceutical enterprises, and 2 other enterprises designated by the local department. 193 of these inspected or spot-checked enterprises were found in violations. In addition, the local department in Shanghai, cooperating with Shanghai Customs by information sharing, enhanced law enforcement on the Hazchem registration of imported Hazchem. This has brought notable results, i.e., the total number of Hazchem import enterprises in Shanghai that completed Hazchem registration increases from 655 (in 2022) to 826 (in 2023).
