China Hazardous Chemical Registration Overview

With the revival of various industries, the safety of the chemical industry has returned to people's vision. In the past few years, the safety accidents in the chemical industry have emerged in endlessly, which has sounded a heavy alarm to the whole industry. No matter the economic operation of the industry or the situation of safety and environmental protection, they are faced with severe challenges, but also bear huge pressure of public opinion. 

In 2019 alone, 112 people were killed and 717 injured in the top ten accidents in the chemical industry. Behind these bloody figures, we are told that we should understand the safety regulations of dangerous chemicals in the production, storage, use, operation, transportation, disposal and other links of the enterprise, so as to know it well!!           

 For the hazardous chemicals to be produced and imported, the first thing to be done is to register the hazardous chemicals. The purpose is to master the hazard characteristics of the hazardous chemicals themselves, the safety requirements in storage, use and transportation, and the emergency response measures in case of hazardous situations. This small edition introduces the contents related to the registration of hazardous chemicals in China.            

Overview of hazardous chemicals registration            

The measures for the administration of the registration of hazardous chemicals (hereinafter referred to as the measures) were deliberated and adopted at the office meeting of the director general of the State Administration of work safety on May 21, 2012, and promulgated by order No. 53 of the State Administration of work safety on July 1, 2012, and implemented as of August 1, 2012. According to the new measures, hazardous chemical production enterprises and import enterprises shall register hazardous chemicals with the local work safety supervision and administration department responsible for the registration of hazardous chemicals and obtain the registration certificate of hazardous chemicals before they can produce or import hazardous chemicals.           

 Scope of hazardous chemicals registration            

According to articles 2 and 21 of the measures for the administration of the registration of hazardous chemicals, there are two types of chemicals that need to be registered:            

Chemicals listed in the catalogue of hazardous chemicals (2015 Edition);          

  It is not listed in the catalogue of hazardous chemicals (2015 Edition), but it is identified as hazardous chemicals.            

Note: the whole product, including substance or mixture, needs to be registered.            

Type of hazardous chemicals registration enterprise            

According to Article 2 of the measures for the administration of the registration of hazardous chemicals, enterprises producing and importing hazardous chemicals need to register.            

1) Hazardous chemical manufacturer            The newly-built production enterprise shall register the hazardous chemicals before the completion acceptance.          

  2) Dangerous chemicals import enterprise            The import enterprise shall register the hazardous chemicals before the first import. Import enterprises are divided into trade type and use type. The trade type is the direct sale of imported products; the use type is engaged in the production activities of the enterprise with imported dangerous goods as raw materials.            

The measures for the administration of the registration of hazardous chemicals (Order No. 53) states that if the same enterprise produces or imports hazardous chemicals of the same variety, it shall register once according to the production enterprise, but shall submit the relevant information of the imported hazardous chemicals.            

If a production enterprise or an import enterprise imports dangerous chemicals of the same type from the same manufacturer for many times, it shall only be registered once.            

Registration of hazardous chemicals          

  The registration of hazardous chemicals consists of two parts: online electronic registration and paper material submission. The electronic registration includes:            

（1） Classification and label information, including hazard category, pictogram, warning words, hazard description, prevention description, etc. of hazardous chemicals;            

（2） Physical and chemical properties, including physical properties such as appearance and properties, solubility, melting point and boiling point of hazardous chemicals, chemical properties such as flash point, explosion limit, spontaneous combustion temperature and decomposition temperature;            

（3） Main uses, including legal uses, prohibited or restricted uses of products recommended by the enterprise;            

（4） Hazardous characteristics, including physical, environmental and toxicological characteristics of hazardous chemicals;            

（5） The safety requirements for storage, use and transportation include the requirements for building conditions, warehouse conditions, safety conditions, environmental sanitation conditions, temperature and humidity conditions, the safety requirements for use include the operating conditions during use, protective measures for operators, on-site hazard control measures, etc., and the safety requirements for transportation include the requirements for transportation or Requirements of transportation mode, means of transmitting hazard information to relevant transportation personnel, safety measures during loading and unloading and transportation, etc;            

（6） Emergency response measures in case of hazardous situation, including emergency response methods in case of fire, explosion, leakage, poisoning, suffocation, burn and other chemical accidents in the process of production, use, storage and transportation of hazardous chemicals, emergency consultation service telephone, etc.            

When registering hazardous chemicals, the registration enterprise shall submit the following paper materials and be responsible for the authenticity of their contents:            

（1） Dangerous chemicals registration form in 2 / 3 copies (specific requirements of different regions);            

（2） One copy of the industrial and commercial business license of the production enterprise, the registration form of the foreign trade operator of the import enterprise, the qualification certificate of the import and export enterprise of the people's Republic of China, the approval certificate of the foreign investment enterprise of the people's Republic of China or the approval certificate of the overseas Chinese investment enterprise of Taiwan, Hong Kong and Macao;           

 （3） One chemical safety technical specification and one chemical safety label that are consistent with the hazardous chemicals produced and imported and meet the national standards;            

（4） One copy of emergency consultation service telephone number or power of attorney meeting the provisions of Article 22 of these measures;          

（5） Registered standards for hazardous chemicals (if national standards or industrial standards are adopted, the adopted standard number shall be provided).

Our services           

 1. Registration system enterprise user registration            

2. Communication with registration authority before registration           

 3. Preparation and submission of hazardous chemicals registration materials            

These include          

  (1) Screening of hazardous chemicals, highly toxic chemicals, non pharmaceutical precursor chemicals, precursor chemicals and key regulated hazardous chemicals        

  (2) Data retrieval and collection of physicochemical, toxicological and ecotoxicity         

  (3) Safety conditions and risk control measures for storage and transportation of hazardous chemicals          

  (4) Emergency measures for leakage, fire and poisoning accidents           

  (5) Preparation or revision of SDS and safety labels         

  (6) Assist declaration enterprises to sign 24-hour emergency rescue consultation service agreement with NRCC or local registration office            

4. Preparation and submission of change application materials            

5. Follow up communication with registration authority