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China MEP is considering reopening China’s IECSC supplementation. However, so far no official announcement has been made publicly and there is no definite information as to when the supplementation will start. The only certainty is that the scope of this new round of IECSC supplementation would be the same as the last one i.e. only substances manufactured or imported into China before 15 Oct 2003 would be eligible.
China MEP issued Notice 1366 of 2011 suspending IECSC Supplementation on 18 Nov 2011. Prior to the issuance of this notice, companies could apply for IECSC inclusion according to SEPA Notice 12 of 2007 without supplying any test data if there was proof that the substance had been produced or used in China before 15 October 2003. For companies that missed that chance, China new chemical substance notification (China NCSN) should be complied with if the substances were not listed on IECSC, irrespective of the fact that the substance has been manufactured or imported prior to 15 Oct 2003.
In Dec 2015, the updated China NCSN FAQs (CL news) introduced a situation in FAQ No.196 that if a substance is listed in China’s Inventory of Hazardous Chemicals but has not been listed in the IECSC, the substance will still need to be notified. IECSC doesn’t include all substances managed by other existing regulations and cases do exist where different ministries manage different inventories according to their own substance assessment and management criteria (e.g. hazard properties). These management systems do not take the 15 Oct 2003 cutoff date into consideration. For example, 1,5-Diaminopentane (CAS No. 462-94-2) is an example of the situation outlined in No.196.
In addition, there are numerous cases of stakeholders that fulfill IECSC supplementation criteria but missed the supplementation. The potential of China MEP restarting IECSC supplementation is a promising development for these companies. It should be noted that before actual implementation of another supplementation program, it is still illegal to manufacture or import any new substances in China before acquiring a NCSN notification certificate.
