By Little Pro on 2015-12-30 Views: Update:2018-02-09
IECSC standards for the Inventory of Existing Chemical Substances in China. In Jan 2013, China MEP published the updated version of IECSC. There are 45,612 substances in IECSC (2013) among which 8,486 substances do not have CAS numbers. Any substance that is not listed on IECSC is regarded as a new substance in China and requires notification in accordance with China MEP Order 7 (China REACH).
You have two options to access IECSC (2013):
There are 3,270 substances in the confidential section of IECSC. If a substance cannot be found in above list, you may submit a formal enquiry to MEP to check the confidential section to confirm whether your substance is a new substance. This enquiry costs approximately RMB 5,000 (USD 800) per substance.
In 2016, China MEP added 31 substances to IECSC. This list can be downloaded here.
IECSC is not a static inventory. Notified new substances may be added to this inventory 5 years since the date of the first commencement of manufacturing or importation. For a polymer, even if all monomers are listed, polymer notification is required if the polymer itself is not listed. For polymers, it is not worth to check the confidential section because you can submit a simplified notification directly which causes the same amount of money.
If one substance is listed on China IECSC, that does not mean that it is free of any production or import and export control in China. For example, if it is a hazardous chemical, a drug precursor chemical or chemical weapons precursor, it will be subject to stringent license and registration requirements.