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Taiwan launched Phase 1 registration for existing chemical substances manufactured or imported in amounts over 100kg/year on 1 Sep 2015. The information gathered from Phase 1 registration will facilitate the designation of priority existing substances (PECs) subject to Phase 2 registration (standard registration).
Speaking at a seminar held in Taipei on 9 Jun 2017, Mr. Chung-Hao Hsu from Taiwan EPA shared that the PECs list will be released in three separate batches. The corresponding registration timeline has been set as follows:
Batch 1: Jan 1, 2018 – Dec 31, 2020
Batch 2: Jan 1, 2021 – Dec 31, 2023
Batch 3: Jan 1, 2024 – Dec 31, 2026
The tonnage threshold for Phase 2 existing chemical registration is set as 1 ton per year, consistent with EU REACH. In addition, joint submission is mandatory. Manufacturers and importers of the same substance have to submit their registration jointly within the given period.
However, each PEC will be assigned a quota (volume limitation). Exceeding this limitation will be regarded as of “high tonnage” and will mean applicants will have just two years to finish the standard registration rather than the standard three years. For example, if substance A is listed on the batch 1 of PECs with “high tonnage” limitation of 100t, applicants will need to finish standard registration before 2020 if the accumulated amount from all co-registrants exceeds 100t.
The first batch of 122 priority existing chemical substances (PECs) subject to standard registration under Taiwan TCSCA has been drafted. The draft list still needs further internal discussion and will be finalized and published before the end of 2017. Stakeholders should be aware of their obligations and keep in mind the corresponding deadline for registration.
The draft list is accessible here.
* If you are a potential registrant and interested to know more details, please contact us directly at [email protected].
For detailed registration requirements, please refer to the Regulation of New and Existing Chemical Substances Registration and the Guidance for New and Existing Chemical Substances Registration.
It appears that the registration schedule and deadline is overly ambitious given the time required during LR election, data gap analysis, data purchasing, generating testing data, etc. It is also necessary to factor in that it is the first time Taiwan will try to implement the joint submission mechanism and will likely encounter some initial teething problems.
To allay industry concerns, Taiwan authority has promised to collect qualified data generated from industry compliance with other global regulatory frameworks and use it to provide technical support to all registrants.
ChemLinked will keep a close eye on the updates and keep our readers posted.
