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The draft amendment to Taiwan’s New and Existing Chemical Registration Regulation (a.k.a Taiwan REACH) was issued for public consultation in May 2021. The draft proposal included significant changes compared to the current version (CL news). The industry has raised some problems relating to the implementation of the new regulation. To introduce the potential changes and officially clarify many issues and answer the questions raised by the industry, Taiwan’s Toxic and Chemical Substance Bureau (TCSB) held a seminar on July 21, 2021.
The industry expects the authority to take into consideration of the COVID surge in Taiwan from May this year and mull PECs registration deadline extension to the end of 2024, which is one more year than that proposed in the draft regulation. Mr. Yan-Ru Xie, Director of TCSB replied to discuss it later and see if the deadline can be further delayed. He also revealed that the regulation will be finalized soon and hopefully it will be published in August or September.
Another recurring issue raised during the seminar is the review period. Mr. Cheng-Han Jin from TCSB clarified the confusion about why the review period of registration dossier will be extended. He said many enterprises neglected the time consumed for preliminary check which was provided by the authority to guide enterprises to correct some obvious mistakes and ensure the completeness of materials before formal submission of dossier online. Considering that time for preliminary check is currently not included in the official review time stipulated in the regulation, the authority intends to extend the review period and count such time into the official review period. He emphasized that there will be no impact on the time consumed in practice.
Some enterprises suggest the reporting frequency be reduced. Mr. Yan-Ru Xie replied that they will compare with the reporting system of international counterparties and discuss it later. However, this year’s reporting deadline is approaching, and enterprises are urged to finish submission before Sep 30. According to Ms. Ni Ya-hui from the Environmental Resource & Information Co., Ltd. (ERI), about 40% of the registrants have finish annual reporting of the registered new and existing chemical substances. If there is inevitably delay due to the COVID-19 pandemic, a statement can be delivered to the registration center by email or by post.
The draft amendment proposed to exempt controlled chemicals (19 types) designated under the Regulation on Designation and Operation Permission of Controlled Chemicals under OSHA from the scope of regulation. However, an official from the Ministry of Labor (MoL), the competent authority for OSHA regulation recommended not to adopt it and hopes to collect more hazard information of controlled chemicals. According to Mr. Yan-Ru Xie, it needs inter-ministerial communications.
Another issue posed by an industry representative during the Q&A session is registration validity. He asked if the registration validity for the previously completed small quantity registration and simplified registration will be automatically extended to five years. Mr. Cheng-Han Jin confirmed that the registration validity for a registration whose registration number is issued before the revised regulation comes into force will not be extended, while an extension application applied afterward will grant a five-year registration validity. However, if the registration dossier is submitted before the revised regulation comes into force and approved after the revised regulation comes into force, the registration validity will be unified as five years.
The video (in Chinese) of this seminar is available on YouTube. You can click here to explore more.
