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Taiwan Existing Substance Reviewing is in Progress

Grace Ma

Enterprises may submit the related approval document before 31 March 2015 for the chemical substances, which are not in the existing chemical substance inventory. And the chemical substances should be manufactured and imported before 11 December 2014. After the reviewing, such chemical substances can be managed as existing chemical substances. So far, CIRS has helped several enterprises, which are located out of Taiwan, complete the chemical substance reviewing, and those chemical substances will be added into the existing chemical substance inventory.

According to the Article 16 in the Act of New and Existing Chemical Substance Information Registration (will be short as The Act in the following contents) under Toxic Chemical Substance Control Act (TCSCA), the chemical substances that were manufactured or imported before the implementation of The Act and are not listed in the inventory can still be added into the inventory after the reviewing process by the competent authorities. The register has to submit the related approval documents of the previously manufactured or imported chemical substances before 31 March 2015. After the reviewing by the competent authorities, the chemical substances can be registered according to the chemical substance registration regulations.

Similar to REACH regulation, TCSCA also has different requirements for new chemical substance registration and existing chemical substance registration. New chemical substances must be registered before manufacturing or importing; existing chemical substances with manufacturing or importing amount larger than 0.1 ton per year must complete the Phase I registration between 1 September 2015 and 31 March 2016 (similar to pre-registration in REACH). The registration process will be taken place after the notification list published by the competent authorities.

Based on the fact that existing chemical substances can have a longer registration grace period, CIRS advices that enterprises complete the reviewing before 31 March 2015 if their chemical products meet the existing chemical substance reviewing condition, in order to seize the last opportunity to enter the chemical substance inventory.

Taken into consideration that the chemical substance inventory under TCSCA and OSHA are still not unified, and the OSHA inventory amendment has already finished by July 2014. In order to assure the successful trade for enterprises, CIRS advices that, for the chemical substances that have passed the TCSCA existing chemical substance reviewing process, enterprises submit the evaluation report and get the approval of registration document according to Article 11 of the New Chemical Substance Registration and Management Act under OSHA. The approval of registration document has a valid time period for one year. During the valid time period, enterprises can manufacture or import the chemical substance in any tonnage band.

If you wish to know more information about Taiwan TCSCA regulation or if you have any demands for the existing substance review, please do not hesitate to send us an email at info@cirs-group.com or call our Toll-Free number at 4006-721-722. We will be ready to assist you.

References

Qualification of the existing chemical substance reviewing register

  • 1.Register has to be a legal person or natural person that is located in Taiwan to apply for a review.
  • 2.Oversea company can apply for a review through their Taiwan company.
  • 3.Application can also be submitted by the third party agents or importers.

Data Requirement for Existing Substances

  • 1.Basic information of register
  • 2.Chemical substance identification: CAS No., chemical substance Chinese/English name, etc.
  • 3.Annual amount of manufacturing or importing
  • 4.Before 11 December 2014, approval document for manufacturing or importing in Taiwan

    a.Manufactured domestically:
    Material trade certificate or sales contract of the manufactured chemical substances; trade certificate, sales contract or manufacturing or retailing record for selling the manufactured chemical substances

    b.Imported from oversea countries:
    Documents from importers: approval document of the imported chemical substance after inspection; trade certificate, sales contract or approval document of shipment from the manufacturers of the imported chemical substances.

    c.Scientific research:
    Scientific paper or scientific magazine can both be regarded as approval documents for the chemical substance that are used for scientific research

    d.The photo copy of the ID card must be submitted if the applicant is a natural person.

Related Fees of Existing Chemical Substance Review

No administrative fee will be charged.

Duration of Existing Chemical Substance Review

From submission of the documents to the completion of the review, usually it takes 14 business days.

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