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‘China REACH’: Assessing the implications for non-Chinese companies producing and exporting new substances to China

Gareth Callagy

elni Review 2011, Issue 1,  pp. 2-7.https://doi.org/10.46850/elni.2011.001

Legislation concerning the environmental management of new chemical substances in China was amended on October 15 2010 by the enactment of the Measures for the Environmental Management of New Chemical Substances by the Chinese Ministry of Environmental Protection (MEP).
Viewed in the context of the implementation of REACH and the ongoing implementation of GHS in China, the amended regulation incorporates some concepts also included in REACH such as GHS-based criteria hazard communication, registration tonnage bands, post-notification tracking and acceptance of notifications only by legal-entities within the jurisdiction of the regulation. The amended measures aim to control the environmental risk posed by new chemicals to ensure public health and ecological maintenance. Despite many significant differences existing between REACH and the China REACH, most notably in the registration scope and testing requirements, the comparison can be used as a frame of reference for non-Chinese companies formulating a compliance strategy.

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References

 

  1. Measures for the environmental management of new chemical substances, Ministry of Environmental Protection, October 15 2010.
  2. Regulation (EC) no 1907/2006 of the European Parliament and of the Council of 18 December 2006concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), establishing a European Chemicals Agency, amending Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and Commission Directives 91/155/EEC, 93/67/EEC, 93/105/EC and 2000/21/EC, OJ 2006 L 396/1.
  3. The Global Harmonised System of Classification and Labelling of Chemicals (GHS).
  4. Baocheng, Wang, New Chemicals Notification Seminar (October 25 2010) Beijing China, CRC-MEP.
  5. Emerging Markets Group, Ltd., & Development Solutions (2005). Chemicals Sector: Forward-looking perspective of EU-China, 2005-2015 Brussels: European Commission External Trade.
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  7. Announcement No. 12 (2007) by the Ministry of Environmental Protection.
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  12. Guidelines for the generic name of new chemicals (HJ/T 420-2008).
  13. Information letter 876 (2010).
  14. International Fragrance Association (IFRA).