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China Opens IECSC Supplementation

China’s Ministry of Ecology and Environment (MEE) has reopened the supplementation of China’s Inventory of Existing Chemical Substances (IECSC). The scope of this new round of IECSC supplementation is the same as the last one, i.e. only substances manufactured in or imported into China before Oct 15th, 2003 would be eligible.

Manufacturers, importers, users of chemicals, industrial associations, etc. can submit paper copies and electronically scanned copies of relevant evidence to the MEE and apply for IECSC supplementation before Sep 30th, 2019. The evidence can be invoices, customs declaration, industry statistics, yearbook of chemical industry, documents issued by administrative departments, public publications, etc.

The authority called a halt to IECSC Supplementation in Nov 2011. Before then companies could apply for IECSC inclusion without supplying any test data if there was proof that the substance had been circulated in China before Oct 15th, 2003. However, there are numerous substances which fulfilled IECSC supplementation criteria but missed the supplementation window. Since 2011, the industry has been eagerly anticipating the reopening of the IECSC supplementation.

The applicants should hurry up since they only have three months to supplement the substances. It should be noted that the information of supplemented substances will be made public and the applicants cannot apply for confidentiality.

According to the authority the review process has been greatly simplified. After internal review, the substances will be published for public comments. If no dissenting opinions are raised in 10 days, the substances will be listed into the IECSC.

The reopened IECSC supplementation could be the last chance for stakeholders to supplement their eligible substances into the inventory in this way. It should be noted that before listing into the IECSC through this supplementation program, it is still illegal to manufacture or import or use any “new” substances in China before acquiring a new chemical notification certificate, irrespective of the fact that the substance has been manufactured or imported prior to Oct 15th, 2003.

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