On 7th of Dec 2015 the FAQs on China new chemical substances notification (China NCSN, a.k.a China REACH) were updated on SCC-MEP website. 5 more frequently asked questions were (No.192-196) appended to the previous version. The followings are the main contents of the 5 new FAQs.
According to the China NCSN Guidance, for data derived from expert statement, a biography of the expert should be submitted. The FAQ clarifies that if the biography is in English, it must be accompanied by a Chinese translation.
For new chemical substances that decompose or react when in contact with water or light and all the decomposition products are listed in the IECSC, they are exempt from eco-toxicological test data requirements. However documents verifying the fact that the decomposition products are all listed in the IECSC should be provided.
For overseas notifiers (except for notifiers in Taiwan, HK and Macau), the name of the notifier should be provided in English, and both capital and small letters are acceptable. In addition, the name should be in accordance with the seal of the notifier and with that presented on the agreement for representative agent and commission contract, etc.
The FAQs indicate that manufacture or import activates of new chemical substances in Free Trade Zones are also subject to MEP Order 7, management of which is equivalent to Bonded and Export Processing Zones. This requirement is in line with the draft of revised China NCSN Guidance, issued for public consultation on 25 Jun 2015.
In very rare cases, 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. Furthermore, the obligations listed in the Table “Summary of the industry obligations – 1.1 chemicals specifically listed in the Inventory of Hazardous Chemicals” should be complied with.
