The offline training on compliance of new chemicals and hazardous chemicals was successfully held

On the afternoon of January 19th, 2021, Xin 'anrun (Beijing) Consulting Co., Ltd., together with Japan Chemical Industry Daily, successfully held an off-line training on the latest policy interpretation of new chemical substances management and import and export compliance of hazardous chemicals, in order to further publicize the latest policies on new chemical substances registration and import and export compliance of hazardous chemicals.

 

This training was first explained by Mr. Zhang, who has more than 10 years of experience in registering new chemicals. Mr. Zhang introduced in detail the registration method of environmental management of new chemicals from the main changes of Order No.12, the response to the registration of new chemicals in Order No.12 and the provisions on connecting matters. In addition, Mr. Han, who has rich experience in compliance with dangerous goods, was invited to explain the Interpretation of Regulatory Requirements for Import and Export of Dangerous Chemicals. First, Mr. Han explained the relevant laws and regulations on dangerous goods and dangerous chemicals, and then interpreted the regulatory requirements for import and export chemicals in detail. Finally, he made a specific analysis on the relevant extension of the Export Control Law.

 

The final question-and-answer session was very enthusiastic, and more than 10 senior executives and leaders of Japanese-funded enterprises put forward to the two teachers the difficulties related to the registration of new chemicals and the management of hazardous chemicals that enterprises care about.

 

We listed some questions and answers as follows:

 

Q1: When can the relevant activities be carried out after the filing and declaration in the registration of new chemical substances under Order No.12 is applied in the system? If the filing materials are inaccurate, will the department in charge of ecological environment give a notice?

A1：After filing materials are applied in the system, a filing receipt will be automatically generated in the system, and the applicant can carry out relevant activities. Follow-up, the competent department of ecological environment under the State Council will organize its subordinate technical institutions of chemical substance environmental management to conduct random spot checks on the conformity of the filing materials.

 

(1) If it is considered by spot check that the filing materials submitted by the applicant do not meet the requirements, or are not sufficient to judge whether they meet the filing conditions, the applicant shall make a one-time correction of the relevant materials according to the requirements of the correction notice. After the applicant submits complete, accurate and compliant supplementary materials, the competent department of ecological environment under the State Council shall reorganize the compliance review.

 

(2) If it is found by spot check that the materials for filing do not meet the requirements for filing, and the routine or simple registration certificate should be handled, the competent department of ecological environment under the State Council shall cancel the filing. The applicant shall bear the corresponding legal responsibilities stipulated in the Measures, and apply for routine or simple registration certificate for environmental management of new chemical substances according to the Measures.

 

Q2：Under Order No.12, how to record the post-event record management after obtaining the registration certificate?

A2：Researchers, producers, importers and processing users of new chemical substances shall, in accordance with the provisions of Article 39 of the Measures, establish a record system for the activities of new chemical substances, and truthfully record the activities time, quantity, actual use, implementation of environmental risk control measures and environmental management requirements, and information transmission to downstream processing users. Encourage the use of information and digital means to establish a record system for the activities of new chemical substances. In addition, if the applicant appoints an agent, the agent in China shall perform the obligation of keeping the activity records and data of the new chemical substances.

 

Q3：Do a series of new chemicals produced by laboratory research and development need to be filed?

A3:Production refers to the manufacturing activities that produce new chemical substances through separate or combined chemical reaction processes based on raw materials and ingredients. Therefore, the research and development of new chemical substances in laboratories belongs to production, which needs to be filed according to the requirements of laws and regulations. If the new chemical substances produced are non-separated intermediates, they will be exempted from registration.

 

Q4：What qualifications do you need as an enterprise to import and export dangerous chemicals？

A4：Import: hazardous chemicals registration certificate is required, and hazardous chemicals business license is required if there are substances in the catalogue

 

Export: if it is a factory, it needs to register hazardous chemicals, and if there are substances in the catalogue, it needs a hazardous chemicals production license; If it is a trading company, it needs a hazardous chemicals business license. In addition, if hazardous chemicals are involved in relevant regulatory lists, such as substances in the list of monitored chemicals, additional relevant administrative licenses are required.

 

Q5：I'm a purchasing agent. Do I need the corresponding hazardous chemicals license to buy hazardous chemicals and sell them to customers?

A5：According to relevant laws and regulations, the purchaser has the obligation to review the relevant qualifications of suppliers. At the same time, as a distributor, when selling related chemicals downstream, it should also meet the relevant licensing requirements (for example, chemicals in the sales catalogue should be sold only after obtaining a business license).

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