New PLC Registered in Taiwan Can Opt to Be Listed in Existing Inventory in Advance

More than 500 new substance registrations are for PLC There is increased demand for listing new registered PLC into the TCSI Procedures for TCSI inclusion have been finalized but are still not published. The application fee for confidentiality protection for chemical registration information will be changed based on registration types

Taiwan’s new chemical registration system has been implemented for more than one and a half years. So far companies have completed more than 1,200 new substance registrations, of which over 500 are for polymer of low concern (PLC).

Under Taiwan REACH, PLC is only subject to small quantity registration (easy data submission) if it is manufactured or imported above 1 t/y. After registration, the new PLC will be included in Taiwan’s existing chemical substance inventory (TCSI) after 5 years automatically or the registrant can opt to list it in the TCSI in advance.

There have been increased inquiries for new PLC qualified to be listed into TCSI in advance. Taiwan EPA has expedited its work on the inclusion procedures and discussed with the MoL for details (new chemical registration regulated under both EPA and MoL).

Speaking at CRAC 2016 in Shanghai, China on 20 Sep, Dr. Gengyan Liu, the deputy director of the Chemical Substance Registration Center under Taiwan EPA said the relevant procedures were finalized and some inclusion applications have been approved. The MoL Prefers to announce the newly listed substances every half or one year, and the substance will be listed into the online database immediately if approved. Although the guidance hasn’t been published, stakeholders can contact the authority for detailed information.

Dr. Liu also shared in CRAC 2016 the latest information regarding CBI application fee for chemical substances. At present each CBI application costs NT$12,500 regardless of the registration type. It seems unreasonable taking into concern that fact that

(1) Different registration types correspond to different CBI protection validity (standard registration has 5 years, simplified registration and small quantity registration have 2 years),

(2) Application for extension costs another NT$12,500 every time (A maximum duration of confidentiality protection for chemical registration information is 15 years)

To solve these problems, the revision for chemical registration fee standard has been drafted and submitted to EPA for further discussion.

So far more than 50% of registrants have asked for full or partial confidentiality and the EPA has rejected only a few applications. Information of new substances that have not applied for confidentiality has been uploaded to the online platform for public search. Updated on 19 Sep 2016, the database now includes 145 new chemical substances registered through the small quantity registration type.