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CRC-MEP Clarifies Submission of Annual Report under China NCSN

The registration certificate holders of simplified notification and regular notification (hazardous new chemical substance and hazardous new chemical substances of priority environmental concern) have the obligation to submit annual report to the CRC-MEP. However, for the new chemical substance notified under SEPA Order 17 (replaced by MEP Order 7 since 15 October 2010), the obligation to submit the annual report is exempted.

The submission of 2012 annual report is due on 1 Feb 2013. Before the deadline, the registration certificate holder can revise and submit the annual report multiple times through the submission software.

  Annual Report Template and the Guidance on Annual Report of New Chemical Substances (EN version).

The annual report in both electronic and PDF form stamped with official seal of the registration certificate holder should be submitted through the software, which is now available for download on the CRC-MEP website. The corresponding written documents should be sent to the CRC-MEP.

Highlights 

The 2012 annual report for the first time requires the import information of the country (region) of departure and HS Code. Although no confirmed explanation has been received from the CRC-MEP, it might be a signal that the CRC-MEP would strengthen the supervision over the notification of new chemical substances, according to Martin Hu, the senior specialist in China NCSN from REACH24H,. The sources of imported new chemical substances would be traced.

As for the simplified notification with practical activities recorded, if the same new chemical substance is contained in several different products imported, only the HS Code of the product with the highest concentration of the new chemical substance will be required. However, this procedure would not work for the regular notification with practical activities recorded, for which the information of every batch of the imported new chemical substance, including all the corresponding HS Codes will be required.

The amount of practical activities (ton) refers to the amount of the notified chemical substances manufactured or imported for the last annum. If the new chemical substance exists in preparations or articles, the amount of the new chemical substance should be calculated according to the percentage or concentration.

In case of modification of registration certificate, a modified registration certificate No. will be received in replace of the original one and the annual report will require the information of the annual activities covered under both the original and the modified registration certificates.

The summary information of the registration certificates required in the front page of the annual report will be automatically generated through the submission software according to the information on Form1, 2 and 3 annexed to the annual report. For details, please see Chemlinked news released on 5 Jan 2013.

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