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Registration Certificate Holders under China NCSN Required to Submit Annual Report

On 15 October 2012, the Chemical Registration Center of the Ministry of Environmental Protection (CRC-MEP) released a notice on its website, urging relevant certificate holders under China New Chemical Substance Notification (China NCSN) to supplement the 2011 annual report before 1 November.

According to the Article 36 of the Measures for the Environmental Management of New Chemical Substances(MEP Order 7),  the registration certificate holders for simplified notification and regular notification (hazardous new chemical substance and hazardous new chemical substances of priority environmental concern) have the obligation to submit annual reports to CRC-MEP for the registered substances before 1st February annually. Even though no practical production or import of the new chemical substance for the previous year is carried out in the previous year after sucessful notification , the reporting obligation shall be accomplished.

In total 4567 certificates are involved in this post-notification requirement to submit the annual report concerning the activities of the notified substance over the past year. However, according to the attached name list in the CRC-MEP notice, so far 185 companies for 660 certificates have not submitted the annual report for year 2011. As specified in the Article 44 of the MEP Order 7, the certificate holders failing to submit the annual report shall be fined up to RMB 10,000.

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