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In late March 2021, the Chinese Ministry of Ecology and Environment (MEE) held a two-day seminar, during which its officials further clarified some practical and technical issues in the implementation of MEE Order No. 12 [1], which took effect earlier on January 1 this year, and introduced the online registration system and filing system.
An official noted that there have been some industry concerns about the change in requirements concerning registration certificate holder. According to MEE Order No. 12, only an applicant can be the holder of registration certificate. For foreign businesses which have their substances registered under MEP Order No. 7, though the registration holders are their representatives, they are still required to fulfill some post-registration obligations, such as first-time activity report and annual report, according to MEE Order No. 12 and the transitional arrangements [2].
Meanwhile, since there has been no technical document dedicated to the socioeconomic benefit analysis report, businesses should prepare the report following requirements set forth in the Guidance on Environmental Management Registration of New Chemical Substances [3].
She said that quite a lot of problems have been identified in the spot check of record notifications. Another official added that MEE had received nearly 1,200 first-time applications for record notification, and among all the applications for record notification, 14 percent were for polymers.
The officials also stressed that enterprises shall assume primary responsibilities in regulatory compliance practices and have a clear knowledge of their obligations as applicants or representatives.
