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China MEP is seeking public consultation on 7 new chemical substances registered through regular notification under China New Chemical Substance Notification (China NCSN, commonly known as China REACH). 7 China NCSN certificates will be issued soon if no dissenting opinion is raised until 8 April, 2013.


On June 5-6 of 2013, Chemspec Europe will hold its exhibition in Munich, Germany. REACH24H is invited to give presentations addressing chemical regulatory development in China.


In early April of 2013, REACH24H Consulting Group China is working with Protiviti LLC and TOKAI TECHNO Co., Ltd to organizing the regulatory seminars in both Tokyo and Osaka. These seminars will mainly focus on the China chemical regulations, including China REACH, China RoHS and China GHS.

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Plant extract can be one of the targets which the “China Reach” might cast upon its attention. Many plant extract products consist of substances which are defined by “China Reach” as new substances, as they may usually not be included in IECSC (Inventory of Existing Chemical Substance in China http://www.crc-mep.org.cn/m006/m006_c1.aspx). As has been up in the rise over the past decade, the plant extract is as a marginal industry developing fast and appearing increasingly frequent in pharmaceutical, fine chemical and agriculture industries. Its use is expanding while scientific research is continuing not far behind the trend we’ve seen and that really triggers cases a lot more than ever in their new substance notification under “China Reach”. However the mere notification for plant extract as new substance is, unlike other new chemical substance, far from easy.


Difficulty for purification

The plant extract product is literally the mixture of active ingredients, water and organic solvent. According to “China Reach”, the active ingredient purified from the product is the sole focus by notification. Despite what the regulation dictates, the reality is, as a result of incompetence of current technology, material and equipment and other basically required elements, even if the purification of plant extract were obtained, the substance itself may be swiftly modified in its property and structure far different from that when previously containing in corresponding solvents. it is often difficult to conduct complete purification. Facing more and more cases such as this, the enforcement body—CRC-MEP therefore takes concession as to accepting data generated by mixture that contains the notifying plant extract. Meanwhile, the plant extract features complex compositions, difficulty therefore also exists in analysis of data because of the absence of structural formula, concentration and composition.


What potential notifers confront of

In response to afore-mentioned circumstances, there are questions often raised by those potential notifers as they consider notifying their plant extract under “China Reach”. Usually their confusions may end up with plight on whether they should relinquish the idea of proceeding to the notification. Because CRC-MEP allows company to notify plant extract by its mixture, solvent that contains the same plant extract, however, may differ. Thus, although company A has successfully notified its plant extract, company B, despite its using different solvent to contain the same plant extract, can be the immediate beneficiary 5 years later when, normally, the previously notified plant extract is due to be listed in IECSC in whose substances included are free from notification obligation. It is disputable that since “China Reach” regulation came into force on October 15, 2010, plant extract notification, whatever solvent its notifying mixture might carry, are concluded only by the plant extract as new substance to be notified. The blindness towards solvent can lead to reluctance in fulfilling the “China Reach” obligation many plant extract producers or importers ought to, given that the solvent itself might be exclusively designed that many notifers may consider it as commercially confidential. Indeed, early bird secures only the regulation upon its notifying plant extract with latent risk against its commercial interest looming all the time afterwards. 


Our Suggestion

Information disclosure concerns notifiers during notification of plant extract. REACH24H has been frequently addressed by our clients regarding this issue. We’d suggest notifiers of plant extract, instead of using its CAS number for substance identification, there would be more agreeable option as CRC-MEP has recently approved of its viability on its latest publication of FAQ online. For example: one plant extract has butanediol as its organic solvent, the naming of it may go as: “substance extracted from XXX by water and butanediol at a ratio 1:1”, so as to replace the CAS number for substance identification.

You may also visit the following website for reference:


Meanwhile the latest edition of FAQ published by CRC-MEP will soon meet its English version by REACH24H, you may contact us by This e-mail address is being protected from spambots. You need JavaScript enabled to view it for any questions or needs.


About REACH24H

REACH24H is a China-based consulting firm, specializing in providing chemical regulatory consultancy, agency and technical support. Our main focus covers the major chemical regulations emerged all around the world, such as EU REACH, EU CLP, China Reach, China GHS, etc. We aim at assisting chemical manufacturers, importers and downstream users to effectively meet the chemical regulatory obligations as well as remove chemical regulatory barriers to their business. In recent years, our services have expanded to a larger extent with cutting-edge IT solution provided and partnerships with globally famous regulatory services providers established, such as WERCS, ChemAdvisor, etc. Our comprehensive cooperation with law enforcement bodies such as the ECHA in EU and CRC-MEP in China, ensure our staying at the forefront of regulatory development, helping us seizing the key to the regulatory affairs and trend.

By the end of 2012, Hannah Zhuang the regulatory specialist took a seven-day travel across Germany and Switzerland to bring local companies with the latest trend and updates on Chinese chemical regulation. One of the most important schedules was to attend the users’ conference of PES-Ingenieurgesellschaft mbH, the SDS authoring software company. Hannah was invited to give a speech regarding Chinese regulations at the conference. 140 people in total attended the conference with all of them representatives from local German companies or those from neighboring countries. Hannah’s speech was aiming at providing compliance advices from the perspective of German companies.



Don’t miss out on the opportunity to reconnect with your colleagues and to create new lasting relationships!

From February 25th to 27th this year, REACH24H attended the once-in-a-year GlobalChem Conference. The conference co-hosted by American Chemistry Council (ACC) and Society of Chemical Manufacturers & Affiliates (SOCMA) laid as usual one of its footholds on China-based chemical regulations this year, and invited regulatory affairs specialist of equivalent regulations, Mr. Mai Fung from REACH24H, to address topics covering several of those most heated regulatory setbacks in recent years China.

You may download presentation slide by click here,

for more information you may contact our speicalist Jerry Yan by:

Email: This e-mail address is being protected from spambots. You need JavaScript enabled to view it , or phone 86 0571 870 7546

Corresponding to the <New Chemical Substance Annual Report Template (Trail)>, the software for submission of China Reach annual report is now available for you to download on CRC-MEP’s official website, which is named after “online submission system for new chemical substance annual report”.


To successfully carry out a notification of a new substance under China REACH lays on various factors, but the foremost is to identify this substance and confirm whether it has been already included in the IECSC (Inventory of Existing Chemical Substance in China). In the article, REACH24H will share its experience on identification of substances through IECSC searching, introducing the differences between PC version and web version of IECSC database. Additionally, we will explain the reason why identification of a substance may fail after searching in IECSC database.


On US EASTERN Time Jan 9th 2013 (Jan 10th 2013 BeijingTime), US COMMERCIAL SERVICE will hold a webinar featuring concerned hot-spots in chemical industry. The webinar, entitled as “Registering & Selling Chemicals in China”, is designed to keep you abreast of the registration, importation and transportation of chemicals according to China’s current requirements. Presenters in this webinar include chemical registration expert, advisor, and online marketplace operator of chemicals trading in China, and a US chemicals manufacturer and exporter. Their focus will be on China’s measures for the registration of new chemicals, and recently-introduced requirements governing aspects of hazardous and non-hazardous chemical manufacture, handling, transport, disposal, and safety. The webinar aims at providing discussion of market trends, exposing challenges U.S. exporters potentially face and advice on how to best succeed in the marketplace. What you may benefit from the webinar are as follow:

——Understand China’s new chemical product registration measures and other regulations pertinent to import, transport and safety;

——Obtain details on how to register chemical products in China, touching on cost, timeline, and challenges, and learn about the supervising Chinese government authorities;

——Learn about the latest China market trends, common challenges to import, and how U.S. firms can best address those challenges;

——Ask questions directly of the presenters. Benefit from their on-the-ground perspective and track-record in working with multinational chemical firms in China.

Webinar details

Date: January 9, 2013

Time: 6: 00-7:30 PM US EASTERN (GMT-5), China Time 7:00-8:30 Jan 10 2013(GMT+8)


Chemical Regulatory Barrier in China

As world’s second largest consumer of industrial chemicals, China has also tightening its chemical regulatory supervision and restriction in recent years. Following such regulatory trend, this webinar will invite experts in regulatory affairs to provide guidance in dealing with this trade barrier. Mr. Atlans Dale, the professional regulatory expert from REACH24H Consulting group will bring his in-depth reading of major chemical regulations in China. His main touches are as follow:

(1) China New Chemical Substance Notification: also known as ‘China Reach’ pressuring all chemical manufacturers, importers and downstream users in their manufacture, import or downstream use of new chemicals. Mr. Dale will mainly focus on the key areas during the ‘China Reach’ notification, including authoring of notification dossiers, experiment supervision, overall notification cycle and costs. Earlier, Mr. Dale has also pointed out according to his experience that these issues will largely defer new chemical entering to Chinese market if companies fail to follow proper instructions with careful arrangements

(2) China GHS: including the SDS and label authoring. Chemical companies whether manufacture or export chemicals in China will have to comply with requirements under China GHS. That covers a package of obligations from classification, labeling and packaging of chemicals to be in accordance with Chinese GHS standards, to proper arrangement of SDS authoring and communication along the entire supply chain.


The recognized regulatory expert

This webinar also marks as a milestone for China-based regulatory expert—REACH24H Consulting Group, as its months-long connection with US COMMERCIAL SERVICE will result into their first formal cooperation. The latter convinced the host its competency and professionalism in chemical regulatory affairs based on:

(1) Solid technical background: REACH24H is now armed with a professional team having its members with solid technical background in chemical regulations, toxicology, eco-toxicology.

(2) Rich experience in experiment supervision: As one critical stage during “China Reach” compliance, the experiments carried out by accredited laboratories requires notifiers to be alert at every move during the testing period.

(3) Accurate control on overall notification cycle: the control on overall cycle of “China Reach” notification decides certain notifying chemical when to enter Chinese market. It will either fuel or lessen market competitiveness, and needs more than enough knowing of the regulation itself.

(4) Cost control: Wide-ranging cooperation and profound knowledge of regulatory affairs serves as two essentials that we offer competitive cost control scheme in entire cost upon regulatory compliance.


The Speaker

Atlans Dale, Regulatory Compliance Specialist from China Reach unit of REACH24H.

B.E., Chemistry & Chemical Engineering, China University of Petroleum, 2008

M.S., Marine Chemistry, The 2nd Institute of Oceanography, SOA, 2012

Mr. Dale has been specialized in China Reach and so far is the key member in REACH24H’s technical team. His daily wok combines connecting with accredited laboratory and China Reach enforcement body CRC-MEP (chemical registration center of ministry of environment protection), renders his abundant practical ability in dealing with China Reach.


Other speakers from:

U.S. Commercial Service, Shanghai

eChinaChem, Inc.

Celanese Corporation


If you are interested in this webinar, you may contact our specialist Jason Chan at This e-mail address is being protected from spambots. You need JavaScript enabled to view it (+86 0571 8700 7583) or by directly registering online through:


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