Opinions on China Inventory of Hazardous Chemicals Put forward by REACH24H Experts

Since the issuance of 2013 China Inventory of Hazardous Chemicals (Draft Version), experts from REACH24H Consulting Group have run an exhaustive research on it and put forward their opinions and suggestions. As the open consultation drew a close, feedback from NRCC, SAWS has been received that serious consideration would be taken. ChemLinked reporter revealed some of the suggestions and comments from REACH24H expert, which were presented as follows:

1. Absence of chemicals’ CAS numbers, for example:

2. Wrong CAS numbers

3. Vague expression of “solution”- Water solution only or whatever the solvent is? The suggestion of more specification has been put forward.

4. Neither concentration nor percentage composition specified for some mixtures and alloys

5. Ambiguous chemical names – e.g. Entry 230 Butyltoluene can be taken as both p-tert-butyltoluene (CAS#98-51-1) and o-isobutyltoluene (CAS#36301-29-8).

6. Different entries point to similar chemicals – e.g. both Entry 1046 and Entry 1088 refer to cresols mixtures.

7. Lack of specifications for the constituents of mixtures – e.g. hydrogen and methane mixtures are incorporated in the Inventory as Entry 1740. If nitrogen is added to a mixture of hydrogen and methane, will it be taken as a hazardous chemical? As for Entry 219 and 220, which refer to Battery fluids, acid/alkali respectively, is there any limitation to the pH value and constituents and their concentration?

8. Other substances that have been identified as hazardous in developed regions but not incorporated into the Inventory:

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