Comply with First Taiwan TCSCA Phase I Registration Deadline: Challenges and Compliance Tips

Taiwan

Comply with First Taiwan TCSCA Phase I Registration Deadline: Challenges and Compliance Tips

Little Pro on 2016-02-16

As Taiwan TCSCA Phase I registration deadline 31 March 2016 approaches, we would like to share with you a few compliance tips that may be of help to you.

Under revised Taiwan TCSCA, domestic manufacturers and importers are required to submit Phase I registration for all existing chemical substances (approximately 100,000 substances listed on TCSI) manufactured or imported with a volume >100kg/y to EPA. The deadline of Phase I registration is 31 March 2016. Failure to submit phase I registration may incur a fine of 30,000~300,000 new Taiwan dollars and even a ban on production or import.

The information required for Phase I registration is very simple and includes registrant's contact info, substance identification, quantity, and info on manufacture and uses. It is very similar to EU REACH pre-registration except that the exemption limit (100kg/y) is much lower than EU REACH (1t/y).

The main purpose of Phase I registration is to gather info on volume and uses so that Taiwan EPA can prioritize certain existing substances subject to full registrations under TCSCA.

Challenges and Compliance Tips

Since TCSCA only allows domestic manufacturers and importers to submit Phase I registrations, foreign companies may have to disclose their confidential business info (CBI) such as product composition to their customers in Taiwan so that the importers in Taiwan can comply with TCSCA. To avoid that, foreign companies may disclose the CBI to a third party consultant based in Taiwan, who can then submit the Phase I registration on behalf of the importers in Taiwan as authorized third part representative.

Calculating the accurate volume of a substance imported to Taiwan or tracking the volume of a substance imported to Taiwan in the past 3 years may also be a big challenge for many companies because there are two volume triggers for Taiwan Phase I registrations:

the average amount of existing chemical substances manufactured or imported for three consecutive years is more than 100kg; or
the maximum amount in each of three years is more than 100kg.

Given the very tight deadline, companies can actually submit Phase I registration based on estimated volume and even submit Phase I registrations for substances manufactured or imported with a volume less than 100kg/y. This may reduce the workload of volume tracking and calculation significantly.

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