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Taiwan Environmental Protection Administration (EPA) published the draft amendments to the Regulation of New and Existing Chemical Substances Registration in Sep 2017. After that, authorities received a huge amount of feedback from industry. To better understand the industry’s concerns and practical difficulties, EPA held 3 hearing seminars in May. EPA published the hearing minutes of the seminars which contained the questions enterprises raised.
The minutes include over 100 questions and problems brought up by dozens of enterprises. Some questions that drew a lot of attention included:
Does article 4 of the amendments apply to polymers? If it does, then enterprises have to do the registration for both monomers and polymers which will obviously require considerable financial and time investments. Enterprises suggested that Taiwan implements requirements similar to those stipulated in EU REACH.
For article 13 of the amendments, enterprises claimed that for the expired registration, when there’s no major changes in the registration information, authorities shouldn’t ask enterprise to undertake full registration again. A simple notification should be enough.
Some enterprises were concerned about how cosmetic raw materials would be regulated and managed under the cosmetic regulations and chemical regulations.
The 1st phase registration was 4-5 years ago. So the tonnage of chemicals of many enterprises have changed since then. So enterprises suggested that authorities should accept their current operation tonnage for the registration.
All hearing minutes can be downloaded here. The authorities promised that all questions raised would be discussed internally and the industry’s opinions would be seriously considered.
