Taiwan Expects On-site Inspection of Imported Chemicals

Pre-confirmation on CCIP platform of chemicals before importation to Taiwan is not mandatory at present. Taiwan EPA will conduct on-site inspection of imported chemicals, with priority on inorganic & organic chemicals. Penalties will be imposed on violators with reference to Taiwan TCSCA regulation.

To help the industry better understand the pre-confirmation scheme of chemical commodities before importation and be well-prepared for the post-market inspection, Taiwan EPA held one seminar at the end of September. The seminar proceedings are available here.

The pre-confirmation of chemical commodities on the IT platform of Chemical Commodity Importation Pre-Confirmation has been implemented since 2016, which is at present voluntary. Stakeholders are encouraged to declare and confirm on the CCIP platform before importation if their chemical substances contained in goods are subject to new and existing chemical registration.

The competent authority wants to confirm that chemical goods imported to Taiwan are in compliance with all the requirements under chemical substances registration scheme. The post-market inspection will prioritize inorganic & organic chemicals (corresponding Chapter 28 & 29 of the C.C.C. Code). Punishments for violations of registration requirements found during on-site inspection will be apportioned with reference to Article 35-1 of Taiwan TCSCA.

By cross-matching the data obtained from CCIP IT platform and obtained from Customs, some Taiwanese chemical enterprises will be informed by phone call that they are subject to on-site inspection. The following materials are recommended to keep at hand during the inspection, including:

registration number;
registration certificate;
permit for chemicals and goods (e.g. pesticide license, feed industry license);
document proving the chemical is inapplicable to registration;
inventory of the chemicals and goods;
import declaration, delivery records; and
SDS

In addition, the on-site inspection will also focus on if there are sound chemical management measures and supply chain communication measures. For example:

If there is internal system to identify whether the chemical is subject to registration
If the manufacture/importation amount has been well-recorded
If enterprises preemptively provide registration No./certificate and SDS in selling/delivering chemicals

To learn more about the pre-confirmation requirements, please refer to ChemLinked expert article: Taiwan Chemical Commodity Importation Pre-Confirmation — Self-Declaration Border Control System Introduced.

The authority also offers supporting Guidance document and FAQ for your reference. Please click here to download the documents.