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Two-Year Grace Period to Be Granted for New Chemical Registration under Taiwan TCSCA

1. Two-year grace period will be granted for new chemical substance manufactured/ imported before 31 Dec 2015. 2. Registration certificate validity varies for different registration types.

As specified in the revised Toxic Chemical Substances Control Act (Taiwan TCSCA), the new chemical substance should be registered 90 days before manufacture or importation, which has caused great uncertainty in the industry. Based on this the registration dossier should be prepared very early at least half a month before the implementation of the revised Taiwan TCSCA on 11 Dec 2014 to avoid any disturbances to business activities. The issuance of the registration details of new chemical substances was delayed until recently. Taiwan EPA published the draft Regulation on Registration of New and Existing Chemical Substances on 25 Aug for public consultation.

To allay industry concerns, as drafted in the draft Regulation a two-year grace period will be granted for new chemical substance manufactured/ imported before 31 Dec 2015 with the submission of materials required for low-quantity registration. This registration type only requires basic information of registrant, substance identification and manufacture/use information. When the grace period expires, the new chemical substance should apply for different registration types accordingly (ChemLinked News).

Registration certificate validity varies for different registration types, of which some are eligible to apply for extension when the validity expires. The details are specified as below.

Table 1. Registration Certificate Validity of Different Registration Types

Registration Type Certificate validity Extension
Standard registration 5 years NA
Simplified registration 2 years Apply for extension within 3 months prior to the end of the 2-year period
Low-quantity registration 2 years
Polymer of low concern registration (>1 t/y, applicable to low-quantity registration) 5 years NA


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