Registration of Hazardous Chemicals

Environmental Management on Registration of Hazardous Chemicals

Registrant

Chinese Manufacturers, importers

Chinese Manufacturers, users, importers, overseas exporters

Authority

State Administration of Workplace Safety, order No. 53

Ministry of Environmental Protection, Order No. 22

Registration Content

Mainly information in MSDS, information of the company, and the 24-hr Emergency telephone number

Mainly the environmental impact analysis and control, and enterprise information

Reference Catalogue

<Catalogue of Hazardous Chemicals>

Hyper Toxic chemicals and other chemicals in <Catalogue of Hazardous Chemicals>; <List of Hazardous Chemicals Not Necessary For the Environmental Management on Registration>; <Catalogue of Key Hazardous Chemicals For Environmental Protection>; <Catalogue of China Strictly Controlled Hazardous Chemicals for Import and Export>.

Remark by Randis: All the ‘Catalogues’, ‘List’ above have not been issued yet, while the <Catalogue of Hazardous Chemicals> (year 2002 version) and <Catalogue of China Strictly Controlled Toxic Chemicals for Import and Export> (year 2012 version) can be referred now.

Name of Certificates

(not finalized)

<Hazardous Chemical Registration Certificate for Manufacturer/User>, <Hazardous Chemical Registration Certificate for Importer>

<Hazardous Chemical Environmental Management Registration Certificate for Manufacturer/User>; <Environmental Management Registration Certificate for Chemicals’ Import/Export>; <Release Notice for Chemicals’ Import/Export Environmental Management>

Materials needed for the Registration

(1) Registration Form

(2) 24hr Emergency Telephone number.

(3) GHS classification of the chemical product

(4) information in MSDS, and information on the company.

Manufacturer/User

Import/Export

(1) Registration Form.

(2) Approval on Environmental Impact. Assessment Report of the company.

(3) Emergency Preparedness for Environmental Incidents.

(4) measures on environmental risk prevention and control; waste discharge information and waste disposal situation; environment monitoring results, etc.

Companies manufacturing/using Key Hazardous Chemicals For Environmental Protection shall also compile and submit ‘Environment Risk Assessment Report’.

(1) Registration Form.

(2) Import/Export Contract.

(3) China domestic manufacturer/user’s <Hazardous Chemical Environmental Management Registration Certificate for Manufacturer/User>.

Remark by Randis: this part is applicable only to chemicals in <Catalogue of China Strictly Controlled Hazardous Chemicals for Import and Export>.

Follow-up management

valid for three years

Valid for three years. Annual report and management  is needed.

Currently it is valid for two years. Annual report needed.

Punishment

Upto 100k RMB penalty, and business ordered to suspend.

Upto 100k RMB penalty

Upto 100k RMB penalty. Refuse application for import/export for 3 years.

Actual Implementation schedule

Estimated to be actually implemented within 6 months.

Estimated to be actually implemented 6 months later.

This part is to replace in the future the management on <Catalogue of China Strictly Controlled Toxic Chemicals for Import and Export> which is currently being implanted.