There are three ways to notify under China REACh. If the substance is a new substance, registration is required irrespective of the tonnage. This applies to isolated substances, isolated transported intermediates, preparations, polymers and articles with intended release of new substances.
Substances, polymers and monomers can be notified in three different ways:
- Scientific Research Record Notification (SRRN)
- This type of notification is required for substances produced or imported in low quantities (<0.1 tonne per annum) for the purpose of research and development (R&D). A Scientific Research Record Notification is also required for the import of testing samples, particularly for the compulsory eco-toxicological required to be performed in approved Chinese laboratories. Currently, there have been 8 laboratories approved by the MEP.
- Simplified Notification
- Simplified Notification is generally required for tonnage quantities <1 tonne per annum. There are five special cases of Simplified Notification for which substances have less registration requirements than the general case of simplified notification.
- The different categories of Special Simplified Notification are:
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- Intermediates < 1 tonne per annum
- Manufacture for export only < 1 tonne per annum
- Polymer of low concern (LCPs) with low monomer concentration
- R&D: 0.1 - 1 tonne per annum
- R&D: <10 tonnes per annum over a 2 year period
- Regular Notification
- The general case of Regular Notification applies to tonnage quantities > 1 tonnes per annum. There are four tonnage bands for China REACh:
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- 1st Tonnage Band: 1-10 tonnes per annum
- 2nd Tonnage Band: 10-100 tonnes per annum
- 3rd Tonnage Band: 100-1000 tonnes per annum
- 4th Tonnage Band: 1000+ tonnes per annum
Polymers can be registered under simplified notification or regular notification irrespective of the tonnage quantity.
