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Taiwan Drafts ECSI Inclusion Procedures for New Chemical Substances Registered under Taiwan TCSCA

1. New chemical substances registered under standard registration will have a chance of being included into Taiwan’s ECSI. 2. The inclusion procedure also applies to polymers of low concern although they only require low-quantity registration.

Taiwan Existing Chemical Substances Inventory (ECSI) will be updated based on the Second Supplementary Existing Chemical Substance Nomination (SSECN) before the implementation of the revised Taiwan TCSCA on 11 Dec 2014. The final version of ECSI will serve as the basis for judging whether a substance is new and subject to new chemical registration under the revised TCSCA. The finished ECSI will be appended thereafter through inclusion procedures for registered new chemical substances.

Unlike EU REACH which has no procedure for changing chemical status from “new” to “existing” after registration, Taiwan adopts the similar way of China New Chemical Substance Notification (China NCSN, a.k.a China REACH). New chemical substances registered under standard registration will be listed into Taiwan’s ECSI five years after successful registration. In addition, for polymers of low concern, the five-year procedure timeline also applies although these substances only require low-quantity registration. Other than the two exceptions mentioned above, new chemical substances registered under simplified registration and low-quantity registrations are ineligible for Taiwan ECSI inclusion procedures.

Table 1. Taiwan ECSI Inclusion Eligibility

Registration Type

Taiwan ECSI Inclusion

Standard registration

when registration certificate validity expires (5 years)

Simplified registration

NA

Low-quantity registration

NA

Polymer of low concern registration (>1 t/y, applicable to low-quantity registration)

when registration certificate validity expires (5 years)

However, if new chemical substances are classified as toxic chemical substance, regulators have the power to further regulate it under the current toxic chemical substance management system, regardless of the inclusion procedures.

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