REACH24H Consulting Group

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Displaying items by tag: chemical regulation

On November 3, the two-day Chemical Regulatory Annual Conference (CRAC) 2015 jointly organized by REACH24H Consulting Group, China Chamber of Commerce of Foodstuffs and Native Produce, China Petroleum and Chemical Industry Federation draws to a successful close at XIXI Hotel in Hangzhou, China. The two-day conference provides a feast for compliance discussions, inviting various prestigious officials and business representatives from China, Europe, South Korea, Japan and Taiwan to deliver keynote speeches and share insights on coping strategies and future trends of respective chemical regulations in major economies. CRAC2015 is honored to have had the participation of media friends from Bloomberg, China Chemical Industry News and ChemLinked, government officials from the U.S. Consulate in Shanghai, China’s Ministry of Environmental Protection and the European Chemicals Agency etc. as well as our longtime friends from companies including Schlumberger, AkzoNobel, Cytec and Lubrizol, to name just a few, reaching an unprecedented high of over 180 attendees. Here below is a brief introduction to what’s been most heatedly discussed at CRAC2015.

Analysis of the Status Quo and Future Developments of Chemical Regulations in China

The year of 2015 is by no means an ordinary year for China’s chemical and environmental management. The catastrophic Tianjin Blasts of August 12 ignited an increasing call among the public for risk management of hazardous chemicals. Competent authorities have stepped up efforts for intensified regulation, putting into effect the Inventory of Hazardous Chemicals (2015) on May 1st and its corresponding Implementation Guidance on August 19 as well as releasing the revised China New Chemical Substance Notification Guidance and the Measures for the Environmental Management Registration of Hazardous Chemicals on June 25 and October 19 respectively for public consultation.

During the conference, Ms. Jinye Sun and Ms. Mengsha Zhang from the Division of Chemical Management of MEP-SCC, Deputy Director Kaijian Niu of Division III of State Administration of Work Safety (SAWS), Mr. Zongtao Wu from Ningbo Entry-Exit Inspection and Quarantine Bureau, Mr. Jun Chen from NRCC of SWAS, Mr. Bin Zhu from Shanghai Chemicals Registration Office, Mr. Zhengcai Chen from China Petroleum and Chemical Industry Federation and Mr. Huanyong Du from China Academy of Safety Science and Technology gave quite informative talks on the revision of China New Chemical Substance Notification Guidance and the MEP Order 22, industrial practice of the new Inventory of Hazardous Chemicals, regulation on the import and export of hazardous chemicals, hazardous chemicals registration, dangerous goods with small packages and OSH etc., addressing concerns and confusions raised by the attendees.

Kaijian Niu,Division III of State Administration of SAWS

Zongtao Wu,Ningbo Entry-Exit Inspection and Quarantine Bureau


Jun Chen,National Registration Center for Chemicals of SAWS


Jinye Sun, Division of Chemical Management of MEP-SCC

Particularly, in terms of hazardous chemicals management:

• Deputy Director Kaijian Niu from Division III of State Administration of Work Safety (SAWS) pointed out that the latest Inventory of Hazardous Chemicals is quite different from its previous version. The inventory is an important basis for the safety management of hazardous chemicals in China and its Implementation Guidance serves as a significant implementation reference to help enterprises seek for compliance on the one hand and assist competent authorities to step up supervision on the other hand.

• Mr. Zongtao Wu from Ningbo Entry-Exit Inspection and Quarantine Bureau reminded all relevant importing and exporting companies that hazardous chemicals listed in the Inventory and those not listed in the Inventory with hazards meeting the setting principles of the Inventory are subject to entry-exit inspection.

• Mr. Jun Chen from NRCC of SAWS said that the List of Chemicals Free from the Identification and Classification of Physical Hazards was expected to be released soon. Physical hazards identification organizations are conducting onsite checks and the list will probably be available before January 1st, 2016.

In terms of the environmental management registration of hazardous chemicals,

Ms. Jinye Sun, Director of the Division of Chemical Management of MEP-SCC made an in-depth analysis of some significant changes in the revision of MEP Order 22, including the simplification of registration forms and other material requirements and the replacement of registration certificates with public announcement etc.

Interpretation of Priority Chemical Regulations in Major Areas of the World

In order to help companies better navigate regulatory mazes in major areas of the world to tide over technical trade barriers, CRAC2015 managed to invite many prestigious experts and official representatives from the European Chemicals Agency (ECHA), the United Nation Institute for Training and Research (UNITAR), Japan Chemical Database (JCDB), Korea National Cleaner Production Center (KNCPC), the National Chemical Emergency Centre (NCEC) of U.K., Former U.K. Department for Transport, and Taiwan Environmental Sustainable Development Foundation to elaborate on the latest regulatory development in different countries and regions.

Kevin Pollard from ECHA


Park Peaksoo from KNCPC


Richard Davey from NCEC


Sano Hiroshi from JCDB


Zhaojia Hong, Taiwan Environmental Sustainable Development Foundation


Audience

• Mr. Kevin Pollard from ECHA proposed several valuable compliance strategies for the upcoming 2018 registration deadline, elaborating on ways for preparation of the registration dossier and what to expect of the ECHA compliance check.

• Mr. Park Peaksoo from KNCPC shared his in-depth interpretation of K-REACH with the attendees. He mentioned that consortia for the 510 substances subject to registration under K-REACH are being formed up. The competent authority of South Korea makes it compulsory for companies to join specific SIEF and set up Registration Forum from October 26 to November 30, 2015, after which period companies may be in a passive position if not included in.

• Mr. Richard Davey from NCEC pointed out that China is the most stringent in the world at present in terms of emergency telephone numbers, requiring that a local emergency contact number must be provided and helpline must be manned at all times etc. Chinese authorities sometimes conduct active testing and enforcement.

• Mr. Sano Hiroshi from JCDB and Professor Zhaojia Hong from Taiwan Environmental Sustainable Development Foundation also communicated with the audience their insights on chemical regulation in Japan and Taiwan.

Experience-Based Insights from a Senior EHS Practitioner

To help chemical enterprises well perform their due regulatory obligations and avoid potential risks, CRAC2015 also invited a senior EHS practitioner to share his profound insights on compliance strategies summed up from their practical experiences with peer companies in the industry. Mr. Xiaoyang Ding from Solenis (Shanghai) Chemical Co., Ltd gave a vivid presentation on legal liabilities in packaging, transport and storage of dangerous goods.

Xiaoyang Ding from Solenis (Shanghai) Chemical Co., Ltd


Q&A Session

Mr. Ding discussed possible legal liability issues in the transport, storage and packaging of dangerous goods, the definition of “Legal Liability” and its applicable scope, distinction of statutory obligation from legal liability and analyzed the legal effect and future development of “standards”, gaining warm applauses from the audience with his exceptionally informative and instructive presentation.

Some of the Speakers

CRAC2015 successfully served as a unique channel for technical experts from laboratory, officials from chemical registration center and EHS managers from the world’s leading chemical companies to discuss bumpy circumstances concerning substances needing further scrutiny and to share plans of solution to guarantee efficient and cost-effective compliance.

Highlights of CRAC2015

Welcoming Address by Jim Wei,

General Manager of REACH24H Consulting Group


Opening Speech by Yang Pan,

Director of Zhejiang Institute of Standardization


Ms. Mengsha Zhang from

Division of Chemical Management of MEP-SCC


Mr. Fabrice Clavien from

UNITAR


Mr. Huanyong Du, Deputy Director of

China Academy of Safety Science and Technology


Mr. Zhengcai Chen from

Former Chinese Ministry of Transport


Mr. Jeffrey Hart from

Former UK Department of Transport


Mr. Bin Zhu from

Shanghai Chemicals Registration Office


Highlight


Highlight


Highlight


Highlight

Published in Corporate News

 

OVERVIEW

China is the United States‘ third-largest export market. In recent years China’s chemical regulatory framework has undergone great changes. Chemicals in China are primarily governed by the ‘Regulations on Safe Management of Hazardous Chemicals in China’ (Decree No.591). The complexities of various chemical management regulations in China pose major regulatory and trade barriers for foreign companies. To alleviate these issues REACH24H will host ‘Chinese Chemical Regulatory Compliance Seminar 2014.’ As China’s foremost regulatory compliance service provider REACH24H USA Seminar promises a chance to pick the brains of China’s preeminent regulatory experts, and take home the most up-to-date regulatory compliance information.

(L.A. Seminar is canceled due to schedule arrangement. )

Download Brochure


EVENT SPONSOR


ABOUT THE SEMINAR

This one-day seminar combines an overview of chemical regulations in China and a walkthrough of practical strategies that compliance managers can utilize in responding to compliance issues. This seminar will feature a multitude of practically useful China and Asia-Pacific compliance advice. Participants will be provided with a detailed explanation of major chemical regulations, including China New Chemical Substance Notification, GHS in Asian countries, China Hazardous chemical registration etc. Regulatory elements covered will outline the scope, timeline and requirements of the most significant chemical regulations with an emphasis on the current status, significant changes, and implementation and future trends of chemical regulations in Asia.

Registration Details

Our 10% special discount is available to:

²  Previous REACH24H US Seminars Attendees

²  Chemlinked Standard/Corporate Member

To claim your 10% discount please email Vanccy.hu@cn.reach24h.com

*The registration fee includes all program materials, breakfast, lunch, twice per day refreshments and taxes.

Refund/Cancellation Policy

7 days prior to start of seminar - Full refund

Less than 7 days - 30% refund

If written notice of cancellation is received on or before September 16, 2014, payment will be refunded (exclusive processing fees). 30% refund will be issued for cancellations after September 16, 2014. REACH24H Consulting Group reserves the right to cancel or reschedule a seminar up to 30 days prior to the start date. Registration fee will be returned.

Deadline for registration

One day prior to each seminar

EVENT DATE & ADDRESS

September 26 Cleveland, OH, USA

Cleveland Marriott Downtown at Key Center

127 Public Square, Cleveland, OH

REGISTRATION

To register online with payment via Paypal:

Cleveland, OH

Or, fill out the Registration Form, and send it to Vanccy.hu@cn.reach24h.com

 

AGENDA

Time

Schedule

8:00

Registration; Coffee and Pastries

8:45

Welcome

9:00

An Overview of Chinese Chemical Industry and Regulatory Framework

v  Development of Chinese chemical market

v  Current trend of China chemical regulations in 2014

9:30

Q&A Session

9:40

China New Chemical Substance Notification (China NCSN)

v  Data and laboratory requirements (Lab choices, Acceptable alternative methods etc.)

v  Risk assessment update in 2014

v  Post notification obligations

v  Future trends in implementation and supervision of China NCSN

10:25

Q&A Session

10:35

Coffee Break

11:00

Case Studies on China New Chemical Substance Notification

v  Polymer notification

v  Re-notification and joint notification

v  Special substances notification: self-ignition substance, photolysis substance,  UVCB substance

11:45

Q&A Session

12:00

Lunch

13:00

China GHS Implementation and Compliance

v  China GHS relevant standards update

New GB 30000-2013 “Rules for Classification and Labelling of Chemicals”

New GB/T 17519-2013 “Guidance on Compilation of Safety Data Sheet for Chemical Products”

v  Specific requirements in China: SDS and labeling

v  China GHS versus US HCS

13:45

Q&A Session

14:00

GHS Implementation in Thailand, Malaysia, Vietnam, Philippines, Japan, South Korea and other Asian countries

v  Implementation status quo, scope and timeline

v  Localized adoption of building blocks

14:45

Q&A Session

15:00

Coffee break

15:20

Hazardous Chemical Registration in China

v  Hazardous Chemical Inventory Update

v  Physical Hazards Identification (new domestic testing institutes announced by the NRCC)

16:05

Q&A Session

16:30

Summary & Wrap-Up

The topics listed in the agenda are most requested, in addition to the specific topics noted here, we offer extended coverage of other topics based on your feedback and requirements.

How we do?

Your needs are our priority concern, a questionnaire will be sent to you after your successful registration, and it will help REACH24H to collect and record information about your needs from two perspectives: special requirements of our USA seminars, and extra requests on other regulatory issues in China and other Asian countries, for example, K-reach, Decree 591, China Cosmetics, China Pesticides, Exporting Food to China and so on.

Subsequently, REACH24H will address these concerns and incorporate solutions and explanations into our presentations, and will offer specific materials which are not included in the topics.

After the seminars, attendees will have a chance to engage with our specialists for additional consultation.

 

CONTACT US

Vanccy Hu

E-mail: Vanccy.hu@cn.reach24h.com

Tel: +86-571-8710 3809

Fax: +86-571-8700 7566

Published in Webinar & Seminar

 

OVERVIEW

China is the United States‘ third-largest export market. In recent years China’s chemical regulatory framework has undergone great changes. Chemicals in China are primarily governed by the ‘Regulations on Safe Management of Hazardous Chemicals in China’ (Decree No.591). The complexities of various chemical management regulations in China pose major regulatory and trade barriers for foreign companies. To alleviate these issues REACH24H will host ‘Chinese Chemical Regulatory Compliance Seminar 2014.’ As China’s foremost regulatory compliance service provider REACH24H USA Seminar promises a chance to pick the brains of China’s preeminent regulatory experts, and take home the most up-to-date regulatory compliance information.

(L.A. Seminar is canceled due to schedule arrangement. )

Download Brochure


EVENT SPONSOR


ABOUT THE SEMINAR

This one-day seminar combines an overview of chemical regulations in China and a walkthrough of practical strategies that compliance managers can utilize in responding to compliance issues. This seminar will feature a multitude of practically useful China and Asia-Pacific compliance advice. Participants will be provided with a detailed explanation of major chemical regulations, including China New Chemical Substance Notification, GHS in Asian countries, China Hazardous chemical registration etc. Regulatory elements covered will outline the scope, timeline and requirements of the most significant chemical regulations with an emphasis on the current status, significant changes, and implementation and future trends of chemical regulations in Asia.

Registration Details

Our 10% special discount is available to:

²  Previous REACH24H US Seminars Attendees

²  Chemlinked Standard/Corporate Member

To claim your 10% discount please email Vanccy.hu@cn.reach24h.com

*The registration fee includes all program materials, breakfast, lunch, twice per day refreshments and taxes.

Refund/Cancellation Policy

7 days prior to start of seminar - Full refund

Less than 7 days - 30% refund

If written notice of cancellation is received on or before September 16, 2014, payment will be refunded (exclusive processing fees). 30% refund will be issued for cancellations after September 16, 2014. REACH24H Consulting Group reserves the right to cancel or reschedule a seminar up to 30 days prior to the start date. Registration fee will be returned.

Deadline for registration

One day prior to each seminar

EVENT DATE & ADDRESS

September 26 Cleveland, OH, USA

Cleveland Marriott Downtown at Key Center

127 Public Square, Cleveland, OH

REGISTRATION

To register online with payment via Paypal:

Cleveland, OH

Or, fill out the Registration Form, and send it to Vanccy.hu@cn.reach24h.com

 

AGENDA

Time

Schedule

8:00

Registration; Coffee and Pastries

8:45

Welcome

9:00

An Overview of Chinese Chemical Industry and Regulatory Framework

v  Development of Chinese chemical market

v  Current trend of China chemical regulations in 2014

9:30

Q&A Session

9:40

China New Chemical Substance Notification (China NCSN)

v  Data and laboratory requirements (Lab choices, Acceptable alternative methods etc.)

v  Risk assessment update in 2014

v  Post notification obligations

v  Future trends in implementation and supervision of China NCSN

10:25

Q&A Session

10:35

Coffee Break

11:00

Case Studies on China New Chemical Substance Notification

v  Polymer notification

v  Re-notification and joint notification

v  Special substances notification: self-ignition substance, photolysis substance,  UVCB substance

11:45

Q&A Session

12:00

Lunch

13:00

China GHS Implementation and Compliance

v  China GHS relevant standards update

New GB 30000-2013 “Rules for Classification and Labelling of Chemicals”

New GB/T 17519-2013 “Guidance on Compilation of Safety Data Sheet for Chemical Products”

v  Specific requirements in China: SDS and labeling

v  China GHS versus US HCS

13:45

Q&A Session

14:00

GHS Implementation in Thailand, Malaysia, Vietnam, Philippines, Japan, South Korea and other Asian countries

v  Implementation status quo, scope and timeline

v  Localized adoption of building blocks

14:45

Q&A Session

15:00

Coffee break

15:20

Hazardous Chemical Registration in China

v  Hazardous Chemical Inventory Update

v  Physical Hazards Identification (new domestic testing institutes announced by the NRCC)

16:05

Q&A Session

16:30

Summary & Wrap-Up

The topics listed in the agenda are most requested, in addition to the specific topics noted here, we offer extended coverage of other topics based on your feedback and requirements.

How we do?

Your needs are our priority concern, a questionnaire will be sent to you after your successful registration, and it will help REACH24H to collect and record information about your needs from two perspectives: special requirements of our USA seminars, and extra requests on other regulatory issues in China and other Asian countries, for example, K-reach, Decree 591, China Cosmetics, China Pesticides, Exporting Food to China and so on.

Subsequently, REACH24H will address these concerns and incorporate solutions and explanations into our presentations, and will offer specific materials which are not included in the topics.

After the seminars, attendees will have a chance to engage with our specialists for additional consultation.

 

CONTACT US

Vanccy Hu

E-mail: Vanccy.hu@cn.reach24h.com

Tel: +86-571-8710 3809

Fax: +86-571-8700 7566

Published in Webinar & Seminar

Shanghai, April 27th, 2013

China Chemical Regulations Seminar 2013  successfully ended  in Shanghai this April 27. Over 170 attendees range from industry association to companies of chemical-related fields carved out ,recorded the highest number in REACH24H’s regular seminar throughout year.

The seminar focuses on several popular regulations that affect more and more players in chemical industry,  including China GHS, hazardous chemical application in China and China New Chemical Substance Notification (i.e. China Reach). In addressing topics covering these regulations, experts from REACH24H--Eric Sun and Atlans Dale dissected issues mostly concerned by presenting audiences knowledge, which serves clients’ needs with different background and knowledge base. (Note: you may directly contact regulatory specialist Jerry Yan for the PPT, or visit our Chinese website for on-site presentation video) During the question and answering session, the attendees raised questions not only to the contents in the presentations, but also to the problems occurred in their compliance activities

The enthusiasm too has suggested that in current regulatory framework, companies in China are faced with  increasingly stringent law enforcement in various forms. REACH24H would advise you to take earlier steps in completing obligations imposed by different regulations in China and keep track of the latest development of these regulations as well.

Published in Corporate News

Stewardship & Regulation of China Chemicals (SRCC) Team, is a project team which provides comprehensive China chemical regulatory consulting services. The services offered by SRCC include Comprehensive Substance Evaluation under China Chemical Regulations, China Chemical Regulatory Progress Report, Regulatory Training, Coating Import License Application, China Hygienic Disinfectants and China Veterinary Disinfectants Registration.

Get to Know SRCC Report
REACH24H SRCC Team can provide the Comprehensive Substance Evaluation Report for China Chemical Regulations. The main checkpoints are shown below:
>>Identify all relevant product regulations
>>Identify all items in those regulations that are related to Product Scope
>>Develop a strategy for practical regulatory compliance.
>>Provide advice and inferences relating to future regulatory trends.

Advantages of SRCC Team
>>Years of accumulated regulatory compliance experience
>>Thousands of collected, classified and analyzed China Chemical Regulations
>>Extensive experience in comprehensive substance evaluation under China chemical regulations
>> Domestic and international cooperation
>>Good communication channels with authorities

Why SRCC?
China’s leviathan Chemical industry is the country's third most important economic sector. It has grown in tandem with the rest of China’s economy. Its expansion has come at a cost however and the chemical industries growth has historically levied a heavy environmental toll and sorely taxed the countries environmental management infrastructure and administrative capacity. In an effort to meet the demands of modern day China, the government has implemented sweeping Chemical management reforms. The new system has greatly increased the mandatory requirements on enterprises manufacturing, importing or using chemicals. The most important factor to address when considering compliance with chemical legislation in China is getting correct and accurate information at the start of the process. The main difficulties faced by both indigenous and foreign enterprises are the complex division of labor adopted by Chinese regulatory authorities, a complex legislative system and the intrinsic language barrier.

Who needs this Evaluation Report?
>>China's domestic enterprises
>>Foreign-funded enterprises in China
>>Foreign enterprises pursuing the Chinese market
>>Chemical Trade Association
>>Chemical Chamber of Commerce

About REACH24H
REACH24H Group provides product stewardship & regulatory compliance service for global customers from its three offices – Ireland, Canada and China, assisting international companies to comply with global chemical regulations including the EU REACH, China new chemical substance notification, Global GHS, USA TSCA, etc. REACH24H in-house team consists of global-regulatory experts, toxicologists, environmental risk assessors, chemical engineers and IT software development engineers to provide cost-effective access to the marketplace for the clients. REACH24H Consulting Group is also the sub-company of Centre Testing International Corporation (CTI) , a publicly traded company on the Chinese Stock Exchange(300012.SZ). CTI is China’s leading product testing, inspection, certification, and consulting firm, providing comprehensive services for virtually all consumer products. For more information on REACH24H, please Contact us or visit About us..

Published in SRCC

What is K-REACH?

Korea REACH (K-REACH) refers to ‘The Act on Registration and Evaluation, etc of Chemical Substances’, which was promulgated by the Ministry of Environment of Korea (MoE) and came into force on 1 Jan 2015. The Act is well-known as Korea REACH due to its similarity to the EU REACH regulation. Early in the year of 2016, Korea MoE initiated the amendment of the Act, and on 28 Feb 2018, the newly revised K-REACH regulation was approved by National Assembly and finally implemented on 1 Jan 2019. Under current K-REACH, any company who intends to manufacture or import a new chemical substance for greater than 0.1 t/a or existing chemical substance for greater than 1 t/a shall do registration before manufacture or import. Additionally, K-REACH also adopts the concepts of pre-registration under EU REACH, which requires all >=1t/a existing chemical substances to apply for pre-registration between 1 Jan 2019 to 30 June 2019 to benefit from the grace periods.

How to comply with K-REACH?

K-REACH uses the Only Representative (OR) concept and allows non-Korean companies to register through an OR on their behalf. The Ministry of Environment (MoE) is responsible for the registration and evaluation of chemical substance under K-REACH.

Registration

Substances Subject to Registration

1. New chemical substances (>=0.1 t/a)

2. Existing chemical substances (>=1 t/a)

3. New chemical substances and existing chemical substances designated by MOE for their total domestic volume exceeds the standard set by the Presidential Decree (total 1 t/a for new chemicals, total 10 t/a for existing chemicals)

Registration Types

Existing chemicals: Pre-registration, Joint Registration

1. Pre-registration

Companies who manufacture or import existing chemical substances for greater than 1 t/a shall do pre-registration between 1 Jan 2019 to 30 Jun 2019 to benefit from the grace periods.

2. Joint Registration

After pre-registration, companies will be granted with a certain grace period for their chemicals according to the hazard and tonnage band. They need to do joint registration on same chemicals before the grace period expires, which is similar to EU REACH.

New chemicals: Simplified Registration, Standard Registration

1. Simplified Registration

0.1-1t/a new substances before 31 Dec 2019.

2. Standard Registration

>= 1 t/a new substances & 0.1-1t/a new substances after 31 Dec 2019

Grace Period

1. New substances don’t have grace period, all new chemical substances should be subject to registration prior to manufacture or import.

2. The grace period for 510 PECs has expired since 1 July 2018, now registration of 510 PECs should be finished before manufacture or import.

3. The grace period for existing substances (exclude the 510 PECs) is as below.

Notification

1. New substances < 0.1 t/a

2. Substances that have received exemption approval under previous 'Toxic Chemical Control Act’ (TCCA):

- New substances under 0.1 t/a

- New polymers which is composed of existing monomers and meet one of below criteria:

1) Polymer with Mn over 10,000 D which contains oligomers with molecular weight of less than 1,000 is over 5%, or oligomers with molecular weight of less than 500 is over 2%.

2) Polymer with Mn between 1000-10,000 D which contains oligomers with molecular weight of less than 1,000 is over 25%, or oligomers with molecular weight of less than 500 is over 10%.

3) Cationic polymer

4) Polymer with Mn under 10,000, which contains residual monomer of hazardous chemical, or priority management chemical exceeding 0.1%.

Registration Exemption Application

-Chemical substance imported/manufactured for export-only use, including substance imported/manufactured to make export-only products

-Chemical reagents

-Surface treated substances

-Non-isolated intermediates or on-site isolated intermediates which can be technically blocked from leakage or exposure

-Polymer of low concern (PLC)

-Substances for R&D use

Risk Assessment

1. Risk assessment is required for substances manufactured or imported for 10 tons or more per year

2. Depending on annual tonnage, the deadlines of submitting risk assessment are listed as follows:

Product Notification

Subject to Product Notification

Priority Management Chemicals (PMC) are present in a product exceeding a specific threshold (above 1 ton/year & 0.1% w/w).

What is PMC?

Priority Management Chemicals (PMC) mean risk-posing chemical substances which fall under any of the following criteria. Now PMC list has been announced by MoE which includes two sub-lists with 672 substances in total. The first list (204 substances) will come into force on 1 July 2019. The second list (468 substances) will come into force on 1 July 2021.

-CMR substances and substances with endocrine disrupting properties (EDC)

-Bio-accumulative and persistent substances (vPvB or PBT)

-Substances which may damage organs such as lungs, kidneys after repeated exposure (STOT)

-Other substances which may give the same level of concern

What to Notify?

1. Notifier information

2. Chemical information of PMC

3. Content and hazard information of PMC

4. Exposure information

5. Uses 6. Classification and label

Penalty and fine under K-REACH

Imprisonment for not more than 5 years or by a fine not exceeding 100 million won would be applied to person who does not comply with the relevant obligations under K-REACH. The fine for violation may also imposed on the basis of total sales of the company (no more than 5%) according to the amended K-REACH.

The Ways to Comply with K-REACH


Note: Non-korean companies can prevent their valuable substance information from being disclosed to the public and their importers in Korea while appointing an OR.

Supply Chain Communication


Note: The Ministry of Employment and Labor (MOEL) requires companies exporting chemicals and products into Korea to provide Korea SDS and labeling.

Our Services

  • Only Representative Service
  • New Chemical Substance Search
  • Registration Dossiers Preparation and Submission
  • Lead Registrant
  • Pre-registration
  • Data Sharing
  • Risk Assessment Report Preparation and Submission
  • Product Notification
  • Exemption Application
  • Training and Consultancy on K-REACH
  • Korea Safety Data Sheet (SDS) and Label Preparation
Published in K-REACH

Overview

Enacted on 16 October 1973, the Japan Chemical Substances Control Law (CSCL) was the world’s first to regulate chemicals and control risks. In 2017, the 4th amendment to the Japan Chemical Substances Control Law was passed and will be implemented in phases from April 1, 2018 and January 1, 2019. The Law is intended to manage risks of industrial chemicals both manufactured in Japan and imported, giving the Ministry of Health, Labor and Welfare (MHLW), Ministry of Environment (MOE) and Ministry of Economy, Trade and Industry (METI) oversight authority over these issues.

Parties Covered by CSCL

  • Japanese manufacturers and importers of chemical substances.
  • Foreign companies selling chemical substances to Japan.

Categorizing Chemical Substances under CSCL

The categories of existing chemical substances and newly announced chemical substances    include most chemical substances manufactured, imported and used in Japan. The status of a substance, existing or new, can be confirmed by searching through these lists. Those included in the inventories and assigned with MITI numbers are existing substances while those not are new substances requiring notification under CSCL.

Existing Chemical Substances Management

cscl

Exemptions:

• Solid and liquid waste (excluding those recalled and sold);

• Natural substances and alloys that do not meet the regulatory definition of “chemical substances”;

• Chemical substances used for R&D purposes or as reagents only;

• Articles and products which can be sold over the counter with a volume of less than 20L (such as household detergent);

• Intermediates (produced and totally consumed on site);

• Impurities (<10%, w/w), excluding practices of dilution and artificial mixing practices;

• Chemical substances regulated by other laws (i.e., pharmaceuticals, cosmetics, pesticides, food additives, etc.) except for industrial applications;

• Substances included in the Exemption List.

New Chemical Substances Notification

New substances notified with low hazard risks are regarded as White Substances and will be added into inventory 5 years after its notification. New substances notified with relatively high hazard risks will fall directly into the category of Priority Assessment Chemical Substances or Monitoring Chemical Substances, the result will be announced within 6-12 months.

Exemptions

• Chemical substances used for R&D purposes or as reagents only;

• Natural substances and alloys that do not meet the definition of “chemical substances”;

• Articles and mixtures packaged for final use (such as household detergent);

• Impurities (<1%, w/w), including byproducts, residual materials, indicators, and catalyst etc.

• Intermediates (produced and totally consumed on site);

• Chemical substances regulated by other laws (i.e., pharmaceuticals, cosmetics, pesticides, food additives, etc.) except for industrial applications.

Notification Process

New substances notified with low hazard risks are regarded as White Substances and will be added into inventory 5 years after their notification. New substances notified with relatively high hazard risks will fall directly into the category of Priority Assessment Chemical Substances, Monitoring Chemical Substances or Class I Specified Chemical Substances, the result of which is  announced within 6-12 months.

Our Services

>>Inventory Search and New Chemical Substance Checking

>>Dossier Preparation and Submission of New Substance Notification

>>Formulation of Integral Registration Schemes (Data Evaluation/Gap Analysis/Exemption Analysis)

>>Study Monitoring

>>Communication with Competent Authorities and Experts

>>Training and Consultancy

>>Preparation of SDS and Label

Published in Japan CSCL

Canadian Environmental Protection Act, 1999 (Hereafter referred to as “the Act”) came into force on March 31, 2000. It gives Canadian government the authority to address pollution issues, to manage the very toxic substance and manage the substance in and out Canada.

The Act powers for all phases of the life cycle of a substance or product containing a substance (e.g. Manufacture, import, release, use, etc.). The Act also gives the Minister authority to maintain a Domestic Substances List (DSL). Substances listed on DSL are treated as Existing Chemical Substances in Canada and are managed by the Minister. Their toxicity evaluation and hazard assessment are done by Canada government. Meanwhile, substances that are not listed on DSL are treated as new substances and need file new substance notification.
There is another substance list under the Act, non-domestic Substance List (NDSL). NDSL is the list of substances accepted as being in use internationally (based on US TSCA inventory), but not cover all the other substances not on DSL. Substances on the NDSL still require new substance notification but allow less information submitted and higher allowable import/manufacture volume.
There are different data requirement for different tonnage band and substance types. Please contact us for more information.

Our Services Include:
>>Canada Agent Service 
>>New Substance Notifications (NSNs)
>>NSN Strategy Development
>>Research and Development & Test Marketing & Low volume/low release/low exposure & Polymer Exemptions
>>Testing implementation and monitoring
>>Technical Substantiation Reports Preparation
>>PreTechnical Substantiation Reports Preparation- and Post-Notification Consultation

About REACH24H
REACH24H Group provides product stewardship & regulatory compliance service for global customers from its three offices – Ireland, Canada and China, assisting international companies to comply with global chemical regulations including the EU REACH, China new chemical substance notification, Global GHS, USA TSCA, etc. REACH24H in-house team consists of global-regulatory experts, toxicologists, environmental risk assessors, chemical engineers and IT software development engineers to provide cost-effective access to the marketplace for the clients. REACH24H Consulting Group is also the sub-company of Centre Testing International Corporation (CTI) , a publicly traded company on the Chinese Stock Exchange(300012.SZ). CTI is China’s leading product testing, inspection, certification, and consulting firm, providing comprehensive services for virtually all consumer products. For more information on REACH24H, please Contact us or visit About us.

Published in Canada CEPA

The Toxic Substances Control Act, namely TSCA, was enacted by the US Congress in 1976 and came into effect in 1977, implemented by the US Environmental Protection Agency (EPA). The Act intends to prevent unreasonable risks of injury to human health or the environment as well as to limit, prohibit, or ban chemical substances posing imminent hazards. With several amendments, TSCA has become a prominent regulation for effective chemical substance management. Much attention shall be paid to TSCA compliance by manufacturers and importers with regulatory obligations.

Interpretation of TSCA

Chemical substances under TSCA are clarified as either “existing substances” or “new substances”. Any substance that is not on the TSCA Inventory is classified as a new substance. Several categories of substances such as munitions, food, food additives, pesticides, drugs, cosmetics, tobacco, nuclear materials etc. are managed by other US regulations and exempt from TSCA regulation obligations.

The TSCA Inventory is comprised of two databases, namely the confidential part and the public part. There are over 83,000 chemical substances listed in the inventory. Substances included in the inventory are regarded as existing substances while those not included are classified as new substances. Existing and new substances have different regulatory responsibilities.

Responsibilities of New Substances

Manufactures and importers of new substances must complete a Pre-Manufacture Notice (PMN) if none of the exemption conditions were met. Exempted substances are subject to TSCA regulations but can be exempted under certain circumstances such as low volume, low release, low exposure, R&D, polymer, test marketing etc. The process of PMN is shown below:

Responsibilities of Existing Substances

Our Services

  • Substance Search
  • Consulting Service Package and Training
  • Pre-Manufacture Notices (PMN)
  • PMN Exemptions (Test Marketing, Low Volume, Low Release etc.)
  • Significant New Use Notices(SNUN)

About REACH24H

REACH24H Group provides product stewardship & regulatory compliance service for global customers from its three offices – Ireland, Canada and China, assisting international companies to comply with global chemical regulations including the EU REACH, China new chemical substance notification, Global GHS, USA TSCA, etc. REACH24H in-house team consists of global-regulatory experts, toxicologists, environmental risk assessors, chemical engineers and IT software development engineers to provide cost-effective access to the marketplace for the clients. REACH24H Consulting Group is also the sub-company of Centre Testing International Corporation (CTI) , a publicly traded company on the Chinese Stock Exchange(300012.SZ). CTI is China’s leading product testing, inspection, certification, and consulting firm, providing comprehensive services for virtually all consumer products. For more information on REACH24H, please Contact us or visit About us.

Published in USA TSCA

According to Article II of Regulation (EC) No 1223/2009, 'a ‘cosmetic product’ shall meanany substance or mixture intended to be placed in contact with the various external parts of the human body (epidermis, hair system, nails, lips) or with the teeth and the mucous membranes of the oral cavity with a view exclusively or mainly to cleaning them, perfuming them, changing their appearance and/or correcting body odors and/or protecting them or keeping them in good condition.'

EU Cosmetics Suppliers have to Comply with:
>>EU Cosmetics Directive 76/768/EEC;
>>New EU Cosmetic Products Regulation (EC) No 1223/2009;
>>REACH Regulation (EC) No 1907/2006;

The Cosmetic Directive 76/768/EEC entered into force in 1976 and provided the main rules for composition, labelling and packaging of cosmetic products. From 11 July 2013, Regulation (EC) No 1223/2009 will replace the Cosmetics Directive. However, some of the provisions of Regulation (EC) No 1223/2009 will apply to substances that are carcinogenic, mutagenic or toxic for reproduction (CMR) from 1 December 2010.
The principal aim of this Regulation is to protect public health by harmonizing the previously laws and regulations concerning cosmetic products in the European Union. The Regulation lays down rules on the composition, labelling and packaging of cosmetic products that are to be adopted throughout the EU member states. 

Compliant Responsibility under EU Cosmetics
(i) Safety Report that provides a safety evaluation of cosmetic products, The safety report must contain: quantitative and qualitative composition of the product, information about impurities and information on packaging materials toxicological profiles of the substances used.
(ii) Product Information File (PIF) that the cosmetic product distributor must create and keep for a period of ten years from the last distribution. The Responsible Person (RP) must also have access to the PIF.
(iii) Provisions on Nanomaterials are included for the first time, as the influence of new technological advances is increasingly felt in the cosmetics industry
(iv) EU-wide notification method
Though the legal implementation date, July 11, 2013, of the Cosmetics Regulation is several years away, it is advisable for cosmetic producers, whose products may have long expiry dates, to apply the changes at the earliest opportunity.

Most of cosmetic products belong to chemical preparations (mixtures) under REACH regulation, so each chemical substance or ingredient shall comply with EU REACH. At REACH24H, we offer integrated and cost-effective compliance solutions for the entry of cosmetic products into the EU.

Our Service Includes:
>>Preparation of product information file("PIF");
>>Safety assessment report;
>>Act as responsible person(for non-EU companies);
>>Pre-market notification;
>>Advice on labelling and languages;
>>EU REACH services

About REACH24H
REACH24H Group provides product stewardship & regulatory compliance service for global customers from its three offices – Ireland, Canada and China, assisting international companies to comply with global chemical regulations including the EU REACH, China new chemical substance notification, Global GHS, USA TSCA, etc. REACH24H in-house team consists of global-regulatory experts, toxicologists, environmental risk assessors, chemical engineers and IT software development engineers to provide cost-effective access to the marketplace for the clients. REACH24H Consulting Group is also the sub-company of Centre Testing International Corporation (CTI) , a publicly traded company on the Chinese Stock Exchange(300012.SZ). CTI is China’s leading product testing, inspection, certification, and consulting firm, providing comprehensive services for virtually all consumer products. For more information on REACH24H, please Contact us or visit About us.

Published in EU Cosmetics
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