Request a Demo
Taiwan's chemical registration regulations namely “The Regulation on Registration of New and Existing Chemical Substances” under TCSCA and “The Regulation of New Chemical Substances Registration” under OHSA only authorize domestic importers and manufacturers to appoint a third party representative (TRP) based in Taiwan to assume their chemical registration responsibilities.
Different to the only representative (OR) rules under EU REACH, in Taiwan non-Taiwanese companies will not be able to obtain registration certificate via a TPR. Instead they should use their downstream importers or potential importers to comply with regulations, according to an official from Taiwan EPA. Global trade with Taiwan will be significantly influenced as under EU REACH, China NCSN, or K-REACH, foreign exporters having obtained the registration No. by using an OR can freely adjust volume sold to the downstream importers or even change the importers. Taiwan has however moved away from this practice in favor of a registration scheme that will place much more regulatory obligations on importers.
The registration dossier should be prepared through CHEMIST and then submitted through another online submission platform. The tools are similar to those under EU REACH, i.e. IUCLID 5 for dossier preparation and REACH-IT for dossier submission and other communication. Generally speaking, dossier preparation can be accomplished by anyone or any institute with expertise in dossier preparation in Chinese through the CHEMIST interface. This requirement is without geographical restriction. Submission requirements will now be imposed on importers or manufacturers who are required to login to the online submission platform using their Business Certificate IC Card or the Organization and Group Authentication IC Card (XCA).
Below are two general cases where importers may appoint a TRP.
(1) The non-Taiwanese company (exporter) is willing to provide his importer in Taiwan the substance information and testing data but the importer is not capable of or lacks the time/energy to prepare a registration dossier.
If the importer decides to submit a dosser by himself, the TPR can only provide technical support during dossier preparation. However, if the importer even does not want to submit the dossier, this responsibility the dossier submission can also be handled by a TPR. For dossier submission, the TPR should be based in Taiwan and have obtained an IC Card.
(2) To protect CBI, if a non-Taiwanese company (exporter) would rather not disclose product information to the downstream importers, he can entrust a TPR in Taiwan to be responsible for dossier preparation and submission on behalf of his importers.
It should be noted that, each importer should sign a POA with the TPR and do joint submission. The administrative fee will be charged for each co-registrant. The registration certificate will be issued for each co-registrant, rather than the non-Taiwanese company.
