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On February 24, 2023, China's Solid Waste and Chemical Management Center (SCC) under the Ministry of Ecology and Environment (MEE) held an online training course on the environmental management of new chemical substances. Comprising of 6 sessions, the online course aims to facilitate the industry in understanding the relationship between new chemical management and new pollutants treatment, guide them on how to fulfill post-registration obligations, and provide insights into local supervision.
Ms. Liu Hongying, an official from SCC-MEE, introduced that "the overall implementation of new chemical registration and the strengthening of follow-up management would be of great importance to reinforce source control to curb the generation of new pollutants." As of February 23, 2023, over 20 provinces and cities in China have issued their own work plans for new pollutants treatment, including Zhejiang, Shanghai, Jiangsu, Tianjin, etc. (see figure below). In various provinces and cities, the departments of ecology and environment at all levels consider new chemical registration as the starting point for the local governance of new pollutants. "Local departments will continue strengthening supervision and law enforcement of new chemical management," Ms. Liu added.
In terms of new chemical management, Shanghai is at the forefront in China. With the release of MEE Order No. 12, Shanghai was the first city to issue a notice vowing to strengthen the on-site inspection and law enforcement of new chemical management (CL news). In recent years, the Shanghai Municipal Bureau of Ecology and Environment (hereinafter referred to as the Shanghai Bureau) has carried out special inspections every year. Mr. Wu Jian, an official from the Shanghai Bureau, was invited to make a special report in this regard. In 2022, the Shanghai Bureau carried out on-site inspections for 46 target companies in different industries (see table below).
Industry of the inspected enterprises | Number |
Chemical raw materials and chemical products manufacturing | 18 |
Retail and wholesale | 15 |
Scientific research and technology services | 4 |
Leasing and business services | 3 |
Pharmaceutical manufacturing | 2 |
Business services | 2 |
Instrumentation manufacturing | 1 |
Managed by corporate headquarters | 1 |
Total number of inspected enterprises | 46 |
The inspections conducted by the Shanghai Bureau focused on three key points:
Whether new chemicals have obtained the registration certificates or record notification receipts as required under the MEE Order No. 12.
Whether the information submitted is consistent with reality.
Whether the risk control measures stated in registration certificates have been implemented.
According to Mr. Wu's report, the inspections revealed 58 cases of non-compliance across the 46 inspected companies. Details are illustrated in the chart below.
"Chemicals subject to new chemical registration are found unregistered (19%)" ranks second in the list of non-compliance cases. Mr. Wu emphasized that companies should have a clear understanding of the chemicals they handle. "The Inventory of Existing Chemical Substances in China (IECSC) serves as the basis to judge whether a substance is identified as a new chemical substance subject to registration requirements under MEE Order No. 12. You can check whether the chemical in your product falls under IECSC prior to starting the relevant chemical activity," he suggested.
Ms. Lu Ling from the SCC-MEE commented that the Shanghai Bureau's follow-up management of new chemicals after registration sets an example for other local departments in provinces and cities to learn from and conduct their supervision and law enforcement.
