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Taiwan has a self-governed chemical management system with a distinct legislative and regulatory framework. During ChemCon Europe2018 in Budapest, Dr. Jowitt Li from SAHTECH overviewed Taiwan’s chemical administration and legal framework and also discussed the potential for Taiwan to adopt an OR system.
Dr. Jowitt Li offered some conclusive numbers on Taiwan’s new chemical registration activities citing data from Taiwan TCSB, the toxic chemical and substance bureau. In the past 4 years, Taiwan has completed:
50+ standard registration for tonnage over 1ton/y;
120+ simplified registration for tonnage between 100kg/y~1ton/y;
2,500+ small quantity registration for tonnage below 100kg/y
1,100+ PLC Pre-confirmation
R&D purposes registration for chemicals less than 1ton/y
“Data shows that from the over 3600+ registrations in the past 4 years, more than 60% have been made with a CBI claim” Said Dr. Jowitt Li.
The commonly addressed issues during the registration process is:
Third party representative
Substance identification vs. spectrum justifications
Testing report qualification/quality, e.g. GLP
Report quality and sufficient contents
(new)usage information required for simplified/small quantity registration
“The Only Representative system is on the agenda for discussion, but right now we still implement the third part representative system,” remarked Dr. Jowitt Li.
It is important to remember that in 2019 if a registrant has claimed CBI in the Taiwan Chemical Substance Inventory (TCSI) before, you may get a notification from the authority to check if you want another 5 years CBI protection for your substances (a yes or no answer is sufficient).
For a comprehensive understanding on Taiwan legislation, please check ChemLinked ChemPedia on Taiwan TCSCA, Taiwan OSHA, Taiwan GHS.
