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Guidance for China Reach: some must-know points for identifying new chemical substances through IECSC searching

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.

Comparison between PC version and Web version of IECSC database

 

 

As we all understand, you need to search in the IECSC (2010 database) for the identification of a substance. In the inventory, the information of substances will generally cover 9 items as below:

1)       CAS No.

2)       Recommended Chinese name

3)       Chinese alias

4)       Chinese generic name

5)       Recommended English name

6)       English alias

7)       English generic name

8)       Molecule formula

9)       Structural formula.

Moreover, you would get access to the inventory for chemical substance identification by applying either of the 2 tools, PC version or Web version. Is there any difference between them? Or is there any advantage of each of them?

 

The comparison table of both IECSC search tools

 

PC version (2010 database)

Webversion (2010 database)

Cost

8500CNY (1365USD or 1032EURO)

Freeof Charge

Search

condition

All 9 items open to be searched

CAS#

English or Chinese substance name

Conclusion

Although PC version may not promise 100% success of searching, it does save time by decreasing the uncertainties caused by searching through searching on web version.

1)       Information typed in must be accurate to avoid failure of searching

2)       Result only tells substance included or not

Link

http://www.crc-mep.org.cn/M006/_notes/M006_F1_1.aspx

http://www.crc-mep.org.cn/iecscweb/IECSC.aspx?La=1

Need detailed information or interpretation, please contactinfo@reach24h.com

 

So compared with PC version, web searching seems not that user-friendly.

 

The improving IECSC database is meeting with invalid searching

The IECSC, since the China Reach came into force in October 2010, is also developing, and so far still has its apparent limit. One interesting fact is that not all existing chemical substances are clearly identified through searching with PC version of IECSC, and it is doing even worse through searching on web version when we turn to that for alternative.

 

Let us take polyamide resin for an example. This name which technically represents as a generic name for a broad range of chemical substances, actually has been included in the IECSC database; while based on different ingredients used, the CAS number of polyamide resin product would differ (tons of CAS number such as 105839-21-2, 68139-79-7 or 68410-23-1, etc. found for identification of polyamide resin products). As a result, you may not be capable of easily identifying your polyamide resin product whether it is new substance or not, concerning its CAS number may not be included in the database, nor may its English or Chinese name. The same circumstance also is found in chemical substances such as glycerol-phthalic resin, fatty acid. Many companies who have a series of products all under one generic name to confirm their identifications, usually type into the search tool only the generic name itself, though has been already included, which does not literally stands for a certain derivative product whose CAS number or Chinese/English name may not be included yet.

 

In the early period of the implementation of China REACH, the CRC—enforcement body, took loose attention over the above cases partly in consideration of commercial confidentiality. Such operations were granted as approved before the generic guidance is to be published. Not every potential notifier, however, notice it. As the CRC continues to tighten its supervision upon new chemical substance notification and as the generic guidance is expected to come into being soon, the IECSC searching will certainly be promoted in higher accuracy.

REACH24H Consulting Group suggests that to apply tools properly for your notification would be a good start on your way. However, due to the limit of China REACH itself, far-from-good tools and technical supports from the authorities, notifying companies may still need not only good knowledge but also expertise from compliance professionals.

 

Some knowledge you can use

About IECSC

The IECSC (Inventory of Existing Chemical Substance in China) is an updated version of ‘Existing Chemical Substance List already manufactured or imported in China’, which corresponds with the <Measures of environmental management of new chemical substances> (MEP Order No. 1), namely the ‘China Reach’. It included chemical substances, for commercial purpose, have manufactured, processed, sold, used or imported in China, from January 1 1992 to October 15 2003.

 

The chemical substances included in the IECSC refer to anyorganic or inorganic substances with specialized molecule identification, including:

(1) Substance overall or part of it is the result of chemical reaction, or any compound that naturally exists;

(2) Any element or none-compounded elementide.

 

The IECSC chemical substances include element, compound (including its additive and impurity), by-product, reaction intermediate, polymer, but not the mixture, preparation and article as well those that have been regulated by other regulatory department, including:

(1) Pesticide (when used for manufacture, process or sell);

(2) Tobacco and tobacco product;

(3) Food, food additive, pharmaceutical and cosmetics (when used for manufacture, process, import or sell);

(4) Radioactive substance;

(5) Military product.

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