Companies planning to submit eco-toxicological testing data in their China NCSN dossier are expected to designate a bigger compliance budget for the coming year since the testing charges will rise substantially, according to the insiders’ sources.
Overall, 5 testing institutes are elevating the testing costs for 14 different eco-toxicological testing items, including Guangdong Detection Center for Microbiology (GDDCM), Nanjing Institute of Environmental Science (NIES), Shanghai Academy of Public Measurement (APM), Shanghai Academy of Environmental Science (SAES) and Shanghai Research Institute of Chemical Industry Testing Center (SRICI). According to the statistics, most of potential notifiers should expect an elevation from 3,000 to 30,000 RMB for one single testing item, which is around 30-40% increase compared with the year 2012.
The increase percentages of the 14 testing items quotations from three testing institutes are displayed in the following table.
Testing Items | Reference | Testing Institute A | Testing Institute B | Testing Institute C |
1. Alga growth Inhibition Test | OECD 201 | 50% | 25% | 5.3% |
2. Daphnia Acute Test | OECD 202 | 55.6% | 25% | 5.2% |
3. Fish, Acute Toxicity Test | OECD 203 | 50% | 20% | 7.3% |
4. Activated Sludge Respiration Inhibition Test | OECD 209 | 25% | 16.7% | 0 |
5. Adsorption/Desorption | OECD 121 OECD 106 | 50% | 25% | 0 |
6. Ready Biodegradability | OECD 301A OECD 301B OECD 301C OECD 301D/F | 50% | 20% | 7.5% |
7. Earthworm, Acute Toxicity Tests | OECD 207 | 22.2% | 25% | 8.3% |
8. Inherent Biodegradability Test | OECD 302B OECD 302C | 50% | 16.7% |
|
9. Hydrolysis as a Function of pH | OECD 111 | 0 | 0 |
|
10. Fish prolonged Toxicology Test (14 days) | OECD 204 | 22.2% | 23.1% |
|
11. Daphnia magna Reproduction Test | OECD 211 | 56.3% | 0 |
|
12. Bioaccumulation | OECD 305B OECD 305 | 42.9% | 0 |
|
13. Fish, Chronic Toxicity Test | OECD 210/212/215 | 57.9% | 0 |
|
14. Seed Germination/Root Elongation Toxicity Test | OECD 299 | 87.5% | 50% |
|
Percentage Increase (Avg) |
| 35.5% | 16.4% | 5.8% |
Nevertheless, compared with the eco-toxicological testing fee charged by the international OECD testing institutions, the to-be-listed quotations of domestic testing institutions are still considered to be in the lower league. However, China is not the OECD member country and the eco-toxicological testing data produced by the MEP-approved testing institutions will not be accepted for other far-reaching chemical regulations in other countries, i.e. EU REACH, USA TSCA, etc. Therefore, the charge inflation could not be eased due to their incompatibility with the global regulatory compliance task.
Obtaining the eco-toxicological testing data has never been a trivial task under China REACH. According to the provisions stipulated in the Measures for the Environmental Management of New Chemical Substances (MEP Order 7), acceptable eco-toxicological tests have to be carried out domestically, specifically in one of the 9 MEP-approved eco-toxicological testing institutes (The list is subject to change after the MEP-conducted qualification inspection in 2012). Furthermore, the overloading status of almost all the testing institutions makes the task even more difficult to accomplish.
