Workshop on Registration of Imported Hazardous Chemicals in China Successfully Held in Shanghai and FAQs

The Workshop on Registration of Imported Hazardous Chemicals in China, organized by CIRS, was successfully held in Shanghai on 24th April 2014. More than 90 delegates from large chemical companies such as Dow, AkzoNobel, Evonik, Ashland, Solvay, Kao, and IFF etc attended this workshop.

Mr Zongzhou Guo from the National Registration Centre of Chemicals (NRCC) of the State Administration of Work Safety (SAWS) shared the latest updates of imported hazardous chemicals registration and answered many questions brought up by delegates at this workshop.

According to Mr Guo’s presentation, approximately 500 importers of hazardous chemicals have applied for username and passwords to use NRCC’s online HazChem registration system up to April 2014. Approximately 80 importers have completed registrations and obtained HazChem registration certificates.

He also mentioned that the SAWS are going to cooperate with the General Administration of Quality Supervision, Inspection and Quarantine (AQSIQ) and the General Administration of Customs to strengthen supervision. If the three ministries reach an agreement on this issue, registrations of imported hazardous chemicals will be greatly promoted in China.

Questions & Answers at the Workshop

Below are a sample of common questions and answers provided by Mr Guo:

Q1: One imported chemical product is a mixture with GHS hazard categories and it is not listed on the Catalog of Hazardous Chemicals, shall we register the product? The physicochemical data is obtained from non-qualified institute, can it be accepted? The 24h emergency telephone number on the SDS and label provided by foreign supplier is not a domestic telephone number. Could we add our own domestic emergency telephone number when we register the chemical?

A: Although this mixture is not listed on Catalog of Hazardous Chemicals, it should be registered as it meets GHS hazard classification criteria. Since the detailed rules of SAWS’s Order 60 have not been published, the data from database and general test results are all accepted. The data source is not strictly required at present. However, it must be indicated. The 24h emergency telephone number must be a domestic number and NRCC encourages enterprises to provide their own domestic emergency number.

Q2: My imported product is not listed on the Catalog of Hazardous Chemical and I do not have any data regarding it. The SDS provided by the foreign supplier indicates that it is not classified as hazardous according to GHS. Do I need to register this chemical product?

A: No. Registration is required for chemicals listed on the Catalog of Hazardous Chemicals and chemicals classified as hazardous according to GHS. Your product is judged as a non-hazardous chemical product based on your information, so registration is not required.

Q3: Our company will use one imported hazardous chemical to manufacture new products, and we buy it through a domestic trading company, which company should register the chemical? Our company is located on Jiangsu Province and the trading company is based in Shanghai, which registration office we should register with?

A: The registration body is an importer and it should meet three criteria i) a domestic company, ii) eligible to import, iii) actual party to deal with the foreign supplier. In your case, the company in Shanghai should register it.

Q4: Is there a small quantity exemption for HazChem registrations?

A: There is no small quantity exemption for imported hazardous chemicals at present. Hazardous chemicals should be registered irrespective of volume.

Q5: When will the formal version of new Catalog of Hazardous Chemicals be published?

A: Many enterprises have asked this question, but it’s hard to give an answer indeed. We look forward to its publication.

Background Info

Registration of hazardous chemicals is a new obligation for importers in China under the Regulations on Safe Management of Hazardous Chemicals (Decree 591 of the State Council of China) and the Measures for the Administration of Registration of Hazardous Chemicals (Order 53 of the State Administration of Work Safety (SAWS)).

The chemicals listed in the Catalog of Hazardous Chemicals should be registered with the National Registration Centre for Chemicals (NRCC) prior to importation under SAWS's Order 53 while physical hazard identification shall be carried out by eligible institutes for chemicals with unknown hazard characteristics prior to registrations.


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