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Taiwan Launched Phase 1 Existing Chemical Substance Registration on Sep 1st

Taiwan launched its existing chemical substance Phase 1 registration on September 1, 2015. All existing chemical substance manufactured or imported over 0.1 ton per year (average annual quantity amounting from the previous three years) should be registered. Information including registrants’ information, chemical name (EN/CN, CAS#), annual amount and usage information are required to be submitted to obtain the Phase 1 registration number. A half-year grace period for phase 1 registration has been granted ( 1 Sep 2015 to 31 Mar 2016)

According to the interpretation of the original Chinese regulation, a phase 1 registration No. should be obtained prior to the manufacture and import activities as of the 1st of Sep 2015. In addition, the authority has insisted that it is illegal to manufacture and import exiting chemical substances without a phase 1 registration number. This requirement has come under severe criticism by industry particularly in light of the fact that the update of “Taiwan Existing Chemical Substance Inventory” (TCSI) has been delayed and the online submission system for phase 1 registration only became accessible at the end of August. Although the submission can be made directly if all the dossiers are well prepared, the authority still requires 7 working days for review and approval. Potential registrants have complained that given the current situation and procedural requirements it is practically impossible to complete Phase 1 registration for the hundreds of thousands of existing chemical substances without severely impacting normal manufacture and import activities.

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