Little Pro on 2018-07-11
In China, both new chemical substances and hazardous chemicals require registrations prior to manufacture or importation. New substance registration is similar to EU REACH registration or TSCA pre-manufacture notice (PMN). Many people are only familiar with new substance notification (China REACH) but not with hazardous chemicals registration. In this article, we will try to give you an overview of hazardous chemicals registration in China. We will focus on its legal basis, procedure and info requirements.
The article 66 and 67 of State Council Regulations on Safe Management of Hazardous Chemicals requires that domestic manufacturers and importers of hazardous chemicals register hazardous chemicals with chemical registration offices affiliated with State Administration of Work Safety (SAWS) prior to manufacturing or importation. Detailed registration requirements and procedure are outlined in SAWS's order 53 - The Measures for the Administration of Registration of Hazardous Chemicals.
The main purpose of HazChem registration is to inform authorities of the type of hazardous chemicals which a company deals with in China.
Hazardous chemicals include both hazardous substances and hazardous mixtures. A product (substance or mixture) requires hazardous chemicals registration if:
To be more specific, chemical products classified with the following GHS hazard categories [GHS classification criteria] will require registrations.The criterion is defined in the Catalogue of Hazardous Chemicals (2015).
Note: For a chemical product with unknown physical hazards (i.e, a chemical outside of the Catalog), hazard identification needs to be conducted by qualified institutes as required by SAWS’s order 60 for physic-chemical identification and classification. If the product is identified as hazardous, a registration will be required.
The following info for each hazardous chemical product needs to be submitted online to provincial HazChem registration office which conducts preliminary review and passes complete registration materials to the National Registration Center for Chemicals (NRCC) of SAWS based in Qingdao City. The whole process takes about 2 months.
Registration certificate is valid for 3 years and can be renewed be renewed 3 months prior to certificate’s expiry date. Attached picture is an example of hazardous chemicals registration certificate. The registration certificate lists all hazardous chemicals registered by the registrant.
To access the online registration system, please click the following link. New user needs to be verified by provincial HazChem registration office prior to using the online registration system.
The picture below is the main window after login.
Q1. My company not only produces a hazardous chemical product but also imports the same hazardous chemical product. Shall we register the product as a producer or importer?
A: You only need to register the hazardous chemical product once as a producer.
Q2. My company produces a series of hazardous chemical products with similar composition and the same GHS classification. Do we need to register each product separately?
A: No. You can register them as one product. You need to indicate the concentration range of hazardous ingredients.
Q3. What is the requirement for 24h emergency telephone number?
A: It must be a domestic 24h emergency telephone number. Both domestic importers and foreign manufacturers can provide this number for HazChem registration use.
Q4. How to provide product standard info?
A: If there is national or industry standard available, you can provide standard no. If not, you need to provide the full text of your own enterprise standard.
Q5. Do we have to register intermediate products?
A: Yes if such intermediate products belong to hazardous chemicals.
Q6. Could we submit our own GHS classification?
A: For chemicals listed in the Catalogue of Hazardous Chemicals, you must use mandatory classification. For other hazardous chemicals, self-classification is accepted.
Q7. How we provide physio-chemical data source?
A: You must provide physio-chemical data (such as flash point) and data source. Data source could be authoritative database, literature or your own test report.
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