REACH24H Consulting Group

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Displaying items by tag: chemical management

The U.S. Toxic Substances Control Act (TSCA) final rule on the TSCA Inventory Notification (Active-Inactive) Requirements was published in the Federal Register on August 11, 2017, becoming effective as of the same date. This is the third TSCA framework rule under the 2016 TSCA Reform Act, which requires EPA to designate chemical substances on the TSCA Chemical Substance Inventory as either “active” or “inactive” in U.S. commerce. To accomplish that, EPA finalized the rule requiring industry reporting of chemicals manufactured, imported or processed in the U.S. over the past 10 years. This reporting will be used to identify which chemical substances on the TSCA Inventory are “active” in U.S. commerce and will help inform the prioritization of chemicals for risk evaluation.

The rule on the TSCA Inventory Notification Requirements includes the following provisions:

1、A Retrospective Reporting with the EPA for chemical substances on the TSCA Inventory that were manufactured (or imported) during the ten-year time period beginning on June 21, 2006 and ending on June 21, 2016. The reporting period will begin on the date of the publication of the rule and extend for 180 days, ending on February 7, 2018. Manufacturers and importers must submit electronically a new “Notice of Activity” (NOA) Form A. Once the notices are received by the EPA, the chemical substances will be designated as “active” on the TSCA Inventory.

2、Processors will have an additional 240 days until October 5, 2018 to submit retrospective activity notifications for chemical substances on the TSCA Inventory that were manufactured (or imported) during the ten-year time period ending on June 21, 2016. The reporting period will begin on the date of the publication of the rule and last for 420 days. Processors must submit electronically a “Notice of Activity” (NOA) Form A. Upon receipt by the EPA, the chemical substances will be designated as “active” on the TSCA Inventory.

3、Provided the manufacturer, importer or processor fail to submit the above-mentioned notice in accordance with the TSCA Inventory Notification Requirements, the chemical substances will be designated as “inactive” on the TSCA Inventory.

4、 In order to resume the manufacturing, importing or processing of chemical substances designated as “inactive” on the TSCA Inventory, a Notice of Activity (NOA) Form B will have to be submitted electronically. Upon receipt of such notice, the EPA will change the designation of the substances on the Inventory from “inactive” to “active”. Reporting to the EPA must not take place more than 90 days before the anticipated date of manufacturing, importing or processing of the chemical substances.

5、Certain substances are exempted from reporting including: chemicals reported under the 2012 and 2016 Chemical Data Reporting (CDR) rule; substances notified to EPA since June 21, 2016; and chemical substances normally exempt from PMN reporting (naturally occurring substances, polymers, LVEs, R&D, etc.) unless they are already listed on the Inventory.

6、The reporting process will include registration in the EPA electronic reporting system (CDX), submitter and chemical identity information, and a certification statement. If a specific chemical identity information is claimed to be confidential business information by the manufacturer, said manufacturer and the importer/processor may file a joint submission. Substantiation for CBI must accompany the request.

7、The electronic reporting system is currently open; therefore, companies may submit a Notice of Activity Form A.

REACH24H reminds chemical companies that chemical substances must be reported within 180 days after the date on which the final rule is published in the Federal Register. The Notice of Activity Form A is the mandatory retrospective reporting form, while Notice of Activity Form B is a remedial form in case of an overdue submission. Notice of Activity Form B applies exclusively to substances that have not been manufactured, imported or processed during the 10-year period and are designated as inactive yet need to be resumed. Companies that fail to abide by their reporting obligations may be subject to a fine of $38,000 USD per day of non-compliance.

Chemical and trade companies need to ensure a timely response to sort out the chemical substances inventory of their supply chains and ensure a timely submission, thus avoiding losses or discontinued trade resulting from the company’s failure to meet the deadline. As regards companies that are unfamiliar with the U.S. electronic reporting system, those companies involved in mergers & acquisitions in the last ten years, as well as companies that need to keep confidential business information will face strict reporting period requirements. REACH24H has set up a subsidiary office in the U.S with TSCA experts who can assist our clients with their compliance obligations under TSCA regulations.

REACH24H will also continue monitoring key developments to provide our clients with the latest regulatory information on the reformed TSCA framework regulations. If you require any further information on the U.S TSCA regulations, please contact Ms. Liu Xintong at (China mainland: +86 0571-87007544).

Published in USA TSCA NEWS

Date: 13-15 July (Registration on 12 July)

Registration Fee: RMB 3800 per person (including VAT, event materials)

Early Bird Discount: RMB 3500 per person before 13 June

Seminar Venue: Shanghai Everbright Convention and Exhibition Center International Hotel


The year of 2015 is by no means an uneventful year for China’s chemical and environmental management. Chemical safety accidents occurred frequently, with the catastrophic Tianjin Blasts of 12 August attracting the most attention, igniting a huge public outcry for risk management of hazardous chemicals. More and more companies began to realize that there is no such thing as sustainable development without an environmental friendly chemical management.

Based on these needs, on 13-15 July, the National Registration Center for Chemicals of SAWS, Qingdao Nuocheng Chemical Safety Technology Co.Ltd and REACH24H Consulting Group will host “China Hazardous Chemicals Management Seminar 2016” in Shanghai. This two-day seminar will help companies to understand the current situation of hazardous chemicals management in China and the cost effective ways to comply with the complexities regulations.


Organizer: Qingdao Nuocheng Chemical Safety Technology Co.Ltd

Co-organizer: Association of International Chemical Manufacturers (AICM)

REACH24H Consulting Group

Partner: National Registration Center for Chemicals, SAWS

Who Shall Attend?

  • Relevant personnel from the country’s administrative and managerial departments concerning traffic, transportation, environmental protection, hygiene, industrial information, quality inspection, work safety;
  • EHS managers, managers in charge of product safety and operation and technical and managerial personnel engaged in the chemical import/export, production, packaging, operation, storage and transportation, inspection etc. ;
  • Chemical regulatory compliance specialists and professionals of relevant fields

Major Contents

  • How to comply with Hazardous Chemical Safety Management Regulations?
  • Interpretation on Common Hazardous Chemicals and Dangerous Goods Standards, and In-depth Analysis of Decree No. 60
  • Key Points for China Inventory of Hazardous Chemicals (2015) , Classification, Identification and Registration of China Hazardous Chemicals Management
  • Interpretation of Policies and Management Requirements for China Chemical Import & Export
  • Interpretation of Supervision Policies for Local Chemicals
  • Requirements on Hazardous Chemicals Manufacture, Use, Storage, Distribution, Packaging and Transportation, and Hazardous Waste Management
  • Risk Assessment and Management during the Distribution Process of Hazardous Chemicals
  • Chemical Accident Emergency Rescue and Work Safety Emergency Response
  • Updates on Asia-pacific Chemical Regulations

Registration Fee

RMB 3800 per person (including VAT, event materials)

Early Bird Discount: RMB 3500 per person before 13 June

How to Register?

1. Please click here to register the seminar

2. Or, fill into the Registration Form and send it to us before 7 July

Contact Us

REACH24H Marketing Dept.

Tel: +86-571-87007555


Seminar Venue

Shanghai Everbright Convention and Exhibition Center International Hotel

Address: No.66, Caobao Road, Xuhui Dist., Shanghai, 200235 China

Tel: +86-21 6484 2500

Published in Webinar & Seminar

On November 26, 2015, REACH24H Chemical Regulatory Seminar 2015 was successfully held in Taipei, Taiwan, organized by REACH24H Consulting Group with the gracious support of Importers and Exporters Association of Taipei, Taipei Chemical Supplier’s Association and Medgaea Life Sciences Ltd. The seminar attracted over 120 attendees from many prestigious companies and associations in Taiwan, hailed by many as quite informative and instructive.

With the increasing concern raised by the public over environmental risks control, major countries and regions in the world have stepped up regulation over hazardous chemicals. However, the requirements and scope of chemical regulations in such countries and regions as EU, China, South Korea and Japan are not necessarily alike, posing great challenges to manufacturers, importers and exporters in Taiwan. As the last deadline of May 31, 2018 for REACH registration comes close, what are the opportunities and challenges for REACH compliance? In mainland China, the Guidance for New Chemical Substance Notification (Draft) was released on June 25 this year, what revisions have been made calling for due attention? The diversified practices of GHS troubles many companies in their import and export activities of chemicals, what are the similarities and differences in that between mainland China and Taiwan? How shall companies do to seek for full compliance under K-REACH, Japan CSCL and Taiwan TCSCA/OSHA?

Presentation Communication during Tea Break

At the seminar, all the above mentioned confusions troubling Taiwan companies have been well addressed by REACH24H regulatory specialists. Many attendees spoke highly of the seminar, saying that all the presentations are well prepared and facilitated a comprehensive understanding of regulations in major regions among the attendees. They also applauded the face to face communication with REACH24H regulatory specialists at tea breaks, with their specific confusions well touched upon. REACH24H Consulting Group is highly grateful of the gracious support of all companies and is well motivated to provide better compliance services to all companies including those in Taiwan.

Published in Corporate News

Biggest driver for global compliance activities is EU REACH, China-related occupying 40%


21 January 2012


World-known chemical regulatory information platform, Chemical Watch, has published on 19 January a result of its recent annual survey - “What do you think about Service Providers?”. Preliminary findings found out over two thirds of companies will expand their in-house chemical compliance resources and 62% think about increasing outsourcing compliance activities over the next five years.

Published in The World

China moves centre stage as Asian programmes push ahead


16 December 2011


From Chemical Watch briefing of December 2011/January 2012 ---- Mr. Sean Milmo on behalf of Chemical Watch, reports over the 3rd Hangzhou International Chemical Regulation REACH Workshop 2011 organized by REACH24H and China Petroleum and Chemical Industry Federation.

Published in The World

The Open Seminar on Chemical Management Policies among China, Japan and Korea was held in Beijing, China on 16th September 2009. It attracted hundreds of experts and representatives from all walks of life. RCS also attended the seminar.

Published in Corporate News
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