China New Chemical Registration FAQs - Vol.5

1. For the import of new chemical substances, shall these new chemicals be registered by the oversea exporters or domestic importers?

According to Article 4 and Article 11 of the MEE Order No. 12, new chemical registration certificate shall be obtained before the importation. Either the overseas exporter or the domestic importer actually involved in the importation needs to obtain the registration certificate.

2. If domestic Company A entrusts domestic Company B to produce new chemical substances, shall the new chemical registration be obtained by Company A or B?

The registration shall be obtained by Company B, which is the actual producer of the new chemical substances. However, the entrusting party's information shall be clearly filled out in the application form. It should be noted that Company B should meet the criteria of applicants stipulated in Article 11 of the MEE Order No. 12 and Section 4 of Chapter 1 in the Guidance on Environmental Management Registration of New Chemical Substances (hereinafter referred to as the Guidance).

3. For the import or manufacture of chemicals in the IECSC (Inventory of Existing Chemical Substances in China), how to comply with the environmental management registration requirements for new chemical substances?

You should confirm whether the chemical substance is subject to new usage environmental management or not first. If it is, it is required to be registered in accordance with Section 1 of Chapter 6 in the Guidance.

4. How to check the progress or download the receipt after submitting the Record Notification? When can I start relevant activities after submitting the Record Notification, and what should I pay attention to?

Applicants can check the progress and download the receipt via the official online system (http://zwfw.mee.gov.cn).

According to the Guidance, applicants can start relevant activities after submitting complete materials for Record Notification and receiving the receipt via the official online system. It should be noted that the authority will conduct random spot checks on the compliance of submitted materials. It's suggested that companies carefully prepare materials for record notification so as to avoid any punishment.

5. For the modification of the Regular Registration Certificate or Simplified Registration Certificate for the environmental management of new chemical substances, do I need to apply for a new registration via the online system after receiving the supplement and correction notice?

No. There is no need to fill in a new application form. Please modify and submit the original registration application form according to the supplementary and correction requirements.

6. Can production or trading enterprises that plan to export new chemical substances to China complete the registration application themselves online?

Relevant application materials can be submitted through the online registration system.

7. What types of registration applications can be withdrawn? How to do?

According to Chapter 6, Section 4 in the Guidance, applicants can submit a written application (stating reasons) for the registration application withdrawal before the application approval is granted, only for the following types of submitted applications:

Application for regular registration
Application for simplified registration
Application for new usage registration
Application for change of registration certificate

8. For regular registration or simplified registration, what should be paid attention to when filling out the estimated activity time in the application form?

Applicants should plan well in advance when applying for regular registration or simplified registration, and the estimated activity time should meet the time limit requirements for administrative approval.

9. When filling in the application form for the simplified registration, what are the requirements for the treatment and disposal methods and environmental risk control measures for three wastes (waste gas, waste water, and waste solid)?

Environmental risk control measures should correspond to the "three wastes" treatment and disposal methods, and be described in a targeted manner around the applied new chemical substances.