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Recently, a new round of inspections for new chemical substances (hereinafter referred to as 2023 Inspection) in various districts of Shanghai has been launched, which is time-sensitive and demanding. It’s very likely that a company will be subject to an official on-site inspection two or three days after receiving the inspection notification. The 2023 Inspection is expected to be more general in coverage.
To further strengthen new chemical registration and supervision, the Shanghai Municipal Bureau of Ecology and Environment has conducted an inspection campaign annually in recent years. As per the official statistics, Shanghai conducted inspections of more than 40 companies in 13 districts of the city in 2022. The inspected companies included those that had undergone regular registration, simplified registration, or record notification, as well as companies that had not registered or notified for new chemicals under MEE Order No. 12. This article sorts out the main inspection procedures and specific inspection contents.
Inspection Procedure
Inspection notification
Companies will receive a phone call within a few days before the inspection date, informing the specific date and requiring completion of the "List of Production, Import, and Use of Chemical Substances in the Enterprise" before the inspection. The List should include the following information:
Chemical name (both in Chinese and English)
Trade name
CAS number
Activity type
Uses
Production/outsourcing quantities in the previous year
New chemical substances or existing chemical substances
Explanation of whether new use environmental management registration is required (if any)
Many companies in Shanghai shared with ChemLinked that they have received the List requiring filling. You can download the List here for more details.
Key inspection points
For registered chemicals, the 2023 Inspection focuses on the authenticity of the registered items and the implementation of the matters stated in the registration certificate. More specifically:
Inspection of relevant materials, including business license, registration certificate or record notification receipt, the corresponding registration or notification archives, ledger or relevant records, monitoring reports, or emission concentration calculation reports, etc.
Inspection targeting the on-site conditions of production, processing, use and storage of registered chemical substances. For example, a) Checking relevant equipment and production line scale to estimate the possible quantity of production or usage; b) Checking the discharge and treatment of waste gas, wastewater and solid waste involving new chemical substances, as well as the operation situation of environmental protection facilities and the treatment effects.
Besides, the 2023 Inspection also covers the implementation of post-registration obligations under MEE Order No. 12, e.g., information transmission, first activity report, annual report, records keeping, etc. See ChemLinked previous article: China New Chemical Post-registration Obligations.
For unregistered chemicals, in addition to the chemical management conditions and situations on-site, the 2023 Inspection focuses more on the verification of whether these listed chemical substances are subject to new chemical registration or new usage environmental management registration based on the Inventory of Existing Chemical Substances in China (IECSC) and MEE Order No. 12.
Comments
The 2023 Inspection is currently ongoing in Xuhui District, Baoshan District, and Waigaoqiao Free Trade Zone of Shanghai. The other districts of Shanghai are expected to initiate the inspection successively soon. Companies in Shanghai are hereby reminded to pay attention to the dynamics of law enforcement and inspection of new chemical management matters in their jurisdictions, and prepare compliance self-check and relevant materials in advance.
Under MEE Order No. 12, the new chemical regulatory oversight has become increasingly stringent. To provide a comprehensive understanding of this regulation and the supervisory trends of China's new chemical management, ChemLinked is going to stage a Free Webinar on 13 September 2023. Please click here to save your seat.
