China Reach Interpretation of the connection items of environmental management registration of new chemicals

On April 29, 2020, the Ministry of ecological environment promulgated the measures for environmental management and registration of new chemical substances (Order No. 12 of the Ministry of ecological environment, hereinafter referred to as the measures), which came into effect on January 1, 2021, and the measures for environmental management of new chemical substances (order No. 7 of the Ministry of environmental protection, hereinafter referred to as the order No. 7) were repealed at the same time. China Reach has updated a lot.           

 In order to ensure the orderly continuation of environmental management and registration of new chemicals, the Ministry of ecological environment organized and issued the notice on relevant connection matters of environmental management and registration of new chemicals (Draft for comments) on June 3, 2020, from the date of issuance to June 20, 2020, the notice was open to all organs, organizations, enterprises, institutions and individuals for comments.            

After reading this draft carefully, xiao'an summarized the contents that have a great impact on customers and friends as follows:            Holder of registration certificate            

Notice content:            

The holder of the routine registration certificate shall, in accordance with the provisions of Articles 38, 39, 41 and 42 of the measures, conduct information transmission, data recording and preservation, first activity report and new hazard information report.            

The holder of the simple registration certificate shall record and keep the data in accordance with Article 39 of the measures.            Interpretation: under order 12, information transmission, data recording and preservation, first activity report and new hazard information report shall be undertaken by researchers, producers, importers and processing users. However, if the registration certificate is obtained under order 7, it shall be borne by the holder of the registration certificate. As the holder of the registration certificate, the agent under order 7 needs additional attention.           

 Annual report           

 Contents of the notice: the annual report of new hazardous chemicals for key environmental management shall be submitted in accordance with Article 41 of the measures.           

 Interpretation: only new hazardous chemicals for key environmental management are listed in the draft for comments. It is expected that no annual report is required for hazardous substances and simple registration certificate under the measures.            

Key environmental management risks           

 According to the key environmental management dangerous new chemical substances determined by order No. 7, the new use environmental management registration shall be continued, and the permitted use shall be specified when it is listed in the list of existing chemical substances in China.            

Interpretation: after the key environmental management new chemicals are listed in the list, new use environmental management will be implemented.            

Change of registration certificate            

Notice content:            

If the holder of the routine registration certificate intends to change the information stated in the registration certificate, he shall apply for registration again in accordance with the relevant provisions of the measures and obtain a new chemical substance environmental management registration certificate.           

 If the holder of the simple registration certificate intends to change the information stated in the registration certificate, he shall, in accordance with the relevant provisions of the measures, handle the environmental management record of new chemical substances, or apply for registration again to obtain the environmental management registration certificate of new chemical substances.            Interpretation: under the current order No. 7, the conventional registration certificate only needs to provide corresponding explanations and supporting documents for the change of the name of the holder of the registration certificate and the quantity within the magnitude, without re declaration. It is suggested that all customers and friends check the registration certificate of new chemical substances in hand. If there is a need to change the quantity within the order of magnitude, please contact us as soon as possible for relevant changes.            

New chemical substances accepted under Order No. 7 but not registered before the effective date of the measures            

Notice content:           

 For the environmental management registration and declaration of new chemical substances accepted before the effective date of the measures, if the registration certificate cannot be obtained before the effective date of the measures because the application materials do not meet the requirements or the normal approval process is not completed within the time limit for handling, etc., the environmental management registration of new chemical substances shall be applied for in accordance with the relevant provisions of the measures.            Interpretation: it is only half a year since the "measures" came into effect, which has a great impact on the current regular registration projects. Please give positive feedback to the Ministry of ecological environment before June 20, or give your feedback to xiao'an, and we will submit it on behalf of you.