Priority Management Chemicals (PMC) Compliance in Taiwan: What Enterprises Should Know
Background
In the Taiwan region of China, the management of Priority Management Chemicals (PMC) is governed under the Occupational Safety and Health Act (OSHA), specifically through the Regulations for Governing Designating and Handling of Priority Management Chemicals, which officially came into effect on January 1, 2015.
Drawing from international practices — including frameworks from the EU, Japan, and the United States — Taiwan targets highly hazardous or high-volume chemicals for prioritized assessment and regulatory oversight. Under these regulations, the Ministry of Labor (MOL) maintains a PMC list and requires companies handling such substances to report their activities, enabling authorities to monitor the flow of chemicals of concern and manage significant potential risks based on hazard and exposure assessments.
Companies must submit two types of data: Basic Operator Information and Operational Information. Operators with 100 or more employees must first file within 6 months after a chemical’s designation announcement, while those with fewer employees must do so within 12 months.
Further, depending on the type of substance, ongoing reporting obligations occur annually or semi-annually, and real-time updates are required if the maximum operational quantity — meaning the highest quantity present at any one time — exceeds set thresholds.
Who Must Comply?
The operators defined under the PMC regulations include:
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Manufacturers: Companies that produce PMCs for wholesale, retail, disposal, or use.
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Importers: Companies that import PMCs into Taiwan.
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Suppliers: Companies engaged in the wholesale or retail of PMCs.
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Employers: Businesses or responsible persons who allow workers to handle or use PMCs (including storage).
Operations refer to the manufacturing, importation, supply, handling, or use of Priority Management Chemicals.
Substances Covered in PMC System
The PMC system categorizes substances into three main groups:
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Chemicals hazardous to minors and pregnant or postpartum women
(Article 2, Item 1)
Includes 96 specified chemicals such as yellow phosphorus, chlorine gas, hydrogen cyanide, lead compounds, mercury compounds, and others. -
High-risk substances based on CNS 15030 classification
(Article 2, Item 2)-
Carcinogens, mutagens, and reproductive toxins (CMRs Category 1)
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Respiratory sensitizers (Category 1)
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Serious eye damage or irritation substances (Category 1)
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Specific target organ toxicity substances via repeated exposure (Category 1)
Encompasses 889 chemicals (including mixtures where the listed substances account for ≥1% by weight), 186 CMR Category 1 and 703 non-CMR.
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Other hazardous chemicals designated under CNS 15030 standards
(Article 2, Item 3)
The designated chemical list contains 163 chemicals (including mixtures of listed chemicals). -
Other substances announced by the authorities
Exemptions apply to:
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Industrial waste
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Tobacco and tobacco products
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Food, beverages, drugs, cosmetics
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Finished goods
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Non-industrial consumer products
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Fire extinguishers
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Chemical intermediates undergoing reactions in processing
Reporting Obligations
| Type of Reporting | Deadline | Substances Involved |
| First Reporting | Within 30 days of operational start | All designated PMCs |
| Regular Reporting | Every year between April and September | Article 2, Items 1 and 2 |
| Semi-Annual Reporting | Every January and July | Article 2, Item 3 |
| Dynamic Reporting | Within 30 days of exceeding thresholds | Article 2, Item 3 |
Key Requirements for Reporting
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Hazardous chemicals for minors/pregnant/postpartum women with a content >1%.
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Category 1 CMR-designated substances with a content ≥1%.
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Non-CMR designated substances with content ≥1% and annual operation volume ≥1 ton.
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Hazardous chemicals (Article 2, Item 3) that exceed designated thresholds must report both the threshold-exceeding substances and others operated at the site.
Penalties for Non-compliance
According to Article 43 of the OSHA, failure to report PMC operations properly can lead to fines ranging from NT$30,000 to NT$300,000.
Penalties apply to operators who:
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Submit false or misleading information.
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Fail to correct data errors (such as omissions or miscalculations) within the specified deadline after notification.
Our Compliance Support Services
Pre-Registration Support
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Comprehensive regulatory consulting
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Specialized regulatory training
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Tailored reporting and permitting strategies
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PMC filing and permit application assistance
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Compliance reporting services
Post-Registration Support
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Ongoing consultations with authorities and experts
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Change management for reported information
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Periodic data updates and compliance monitoring
Why Choose REACHA24H?
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Deep Expertise: Decades of experience with Taiwan region of China’s chemical regulatory system and local offices to support your projects directly.
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Strong Technical Capability: A multidisciplinary team with expertise in chemistry, chemical engineering, biology, pharmacology, and environmental science.
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International Service Standards: Multilingual customer support in English, Korean, Japanese, German, and more to ensure seamless communication with global clients.
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Rich Experience: Extensive track record handling chemical compliance services worldwide.
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Exceptional Resources: Partnerships with top laboratories, enabling efficient and professional testing services.
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Trusted Relationships: Established channels of communication with regulatory authorities and domain experts, enhancing the quality and speed of compliance support.
