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Registration Procedures and Information Requirements of China's Hazardous Chemicals

Posted Date:2020/11/13

In China, both new chemical substances and hazardous chemicals need to be registered before they are manufactured or imported. New substance registration is similar to EU REACH registration or TSCA pre-made notification (PMN). Many people are only familiar with the new substance notification (Chinese version of REACH), but not familiar with the registration of hazardous chemicals. In this article, we will give you an overview of hazardous chemical registration in China.

1. Legal requirements

Articles 66 and 67 of the State Council’s Regulations on the Safety Management of Hazardous Chemicals require domestic manufacturers and importers of hazardous chemicals to register hazardous chemicals with the Subsidiary Chemical Registry of the State Administration of Work Safety (SAWS) before manufacturing or importing. SAWS Order 53-"Administrative Measures for the Registration of Hazardous Chemicals" outlines detailed registration requirements and procedures.

The main purpose of HazChem (hazardous chemicals) registration is to inform the authorities of the types of hazardous chemicals owned by companies in China.

Note:

a. The State Administration of Work Safety (SAWS) was renamed the Ministry of Emergency Management of the People’s Republic of China (MEM) in 2018

b. Foreign companies cannot submit hazardous chemicals registration

c. There is no small batch exemption (some countries and regions have this regulation: the European Union, for example)

2. Which chemicals need to be registered?

Hazardous chemicals include hazardous substances and hazardous mixtures. In the following cases, products (substances or mixtures) need to be registered as hazardous chemicals:

1. It is listed in the catalog of hazardous chemicals (2015 edition);

2. It is not listed in the appeal catalog but is determined to be dangerous according to existing data.

To be precise, chemical products classified according to the following GHS hazard categories (GHS classification standards) will require registration. This standard is defined in the hazardous chemicals catalog (2015) (see the specific catalog for details). Here are a few:

Note:

1) The above (chemical substances/mixtures required to be registered) are just a few from the physical, health, and environment, but not all.

2) Another thing to note is that this classification does not include all the classifications covered by the national GHS classification standard "GB 30000. 2013 Series Standards".

3. Registration procedures and information requirements

The following information for each hazardous chemical needs to be submitted online to the Provincial HazChem (Hazardous Chemicals) Registration Office, which will conduct a preliminary review and deliver the complete registration materials to the National SAWS Registration Center for Chemicals (NRCC) in Qingdao . The whole process takes about 2 months.

Information to be submitted:

1. Classification and labeling of the entire product (classification in line with China's GHS standards);

2. The physical and chemical properties of the product (for example: flash point, boiling point, etc.);

3. Main purpose;

4. Dangerous characteristics;

5. Safety requirements for storage, use and transportation;

6. Emergency contact information (24-hour contact number in China);

7. SDS and labels under the Chinese GHS standards.