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China MEP is to establish specific labs for chemical testing, analysis and assessment. These Labs are expected to meet the post-notification supervisory demands of China new chemical substance notification (China NCSN, a.k.a China REACH), according to some insiders' sources.
The capacities and functions of these labs will be primarily aimed at environmental management of chemicals. Environmental management of China new chemical substances regulated under MEP Order 7 will be priority. Under MEP Order 7, new chemical substances can be manufactured or imported when successfully notified and issued with a certificate. The lack of firm local enforcement has led some enterprises to ignore their post-notification requirements under China NCSN. However, it is possible to enlist these labs to evaluate the impact of chemicals on water, soil, atmosphere and the wider ecosystem and assist in reaching post-notification regulatory goals.
China MEP has already promulgated MEP Order 22 for the environmental management of hazardous chemical registration which is considered an important supplement of China’s environmental risk management. MEP 22 came on 1 Mar 2013, while the practical implementation procedures are still in development. It is expected to come into force in 2014 and we could assume that the establishment of these labs will also serve for the post-registration supervision of hazardous chemicals registered under MEP Order 22, rather than merely for new chemical substances, though it is not yet confirmed by the authority.
As planned, the national chemical lab will be established in the Solid Waste and Chemicals Management Center under the Ministry of Environment (SCC-MEP), a new department under the MEP after the merger and restructuring of the original CRC-MEP and the Environmental Management of Solid Waste. However, the eligibility and implementation dates of this program for regional labs, is still under discussion. Labs will be established on a regional basis, e.g. Eastern China, Southern China, North China, North-West China, etc.
There is widespread concern in the industry that despite implementation of MEP Order 7, many companies are simply ignoring it, creating an unfair playing field for many of the more conscientious companies. China’s national environmental investigation of chemical production was completed last year. The investigation also targeted new chemical substances. The results and analysis of the investigation data should be finalized this year. However, whether or not the MEP will disclose the data without reservation and impose more stringent management on the industry is still unclear. We suspect that maybe the authority is adopting a cautious approach in linking the conduction of the national investigation and the establishment of national and regional labs.
MEP has authorized local environmental protection departments to penalize companies in the order of RMB 10,000 to RMB 30,000 if violations of MEP Order 7 are found, including those involving the manufacture or importation of new chemical substances without a certificate. Many in the industry believe that the enforcement of MEP Order 7 will be diminished since the MEP Order 7 authorized supervision and punitive powers to local authorities. The establishment of these labs will be a chance to strengthen the enforcement of China NCSN and refute the common excuse that regional capacities issues are to blame for many of China environmental management enforcement issues.
At present only 11 eco-toxicological testing institutes are managed by the MEP, however, it is expected that in the near future the MEP will designate its own approved testing institutes to provide physicochemical and toxicological data for China NCSN. It is worth noting that the physicochemical and toxicological labs are different from the labs for chemical testing, analysis and assessment. MEP is now planning to assess the capacity of relevant Chinese labs qualities under quality systems and experimental abilities criteria.
The complete construction of laboratories will still need some time. The annual Lianghui (National People’s Congress and Political Consultation Congress) have finished, and it will review and approve the budget and the funds allocated for construction of these labs, particularly the national lab. However, for regional laboratories, the details are still under internal development will be fleshed out in the coming months.
