New Chemical Substance Registration to Save Money

Release time:

2019-09-06 14:45

Undoubtedly, the registration fee of hundreds of thousands of yuan or even millions of yuan has deterred many domestic enterprises. In this regard, industry experts also put forward suggestions for enterprises to save registration costs.
Experts said that there are three categories in the new "Measures": regular, simple and scientific research filing declaration. According to the tonnage and use of new chemical substances, enterprises can choose different declaration types. For example, if the production or import volume is less than 1 ton, it can be carried out according to the basic situation of simple declaration. For the purpose of process research and development and the volume is less than 10 tons, simple special declaration can be considered, different types have different requirements in time and test data, and the corresponding costs are also very different. Enterprises must choose the correct type before preparing for registration to avoid unnecessary losses.
In view of the fact that new chemical substances are classified according to the List, and a large part of the new chemical substances that need to be registered in China have been registered in one or two foreign countries or regions at present, and the requirements for data in chemical registration in different countries are similar, therefore, enterprises can collect relevant test data abroad before registration, as long as the testing institutions have passed the certification and approval of relevant departments of their countries, most of them can also be used in the registration of new chemical substances in the country. This not only avoids repeated experiments, but also saves a lot of money for the enterprise. In addition, in the absence of commercial competition, the two enterprises can join together to register, which can also save a lot of costs.
Experts mentioned that in the new Measures, there is also a case of adding repeated declarations: that is, if two or more declarers declare the same new chemical substance successively, and the later declarer obtains the consent of the former declarer and uses the test data of the former declarer, the new chemical substance can be declared repeatedly. The method of sharing the cost of testing the data shall be agreed upon by the declarant. This is similar to REACH data sharing, but it may be difficult to operate in practice. After all, there is a greater chance of competition between enterprises registering the same substance. But if the two can communicate well, it is also a way to save money.
The main savings are still in the overall arrangement of animal experiments. Experts say, first of all, enterprises should not do all the items in the experimental project, because there is a correlation between chemical experiments. It should be done in stages, according to the first stage of the experiment to determine which experiments do not need to do. This is the most economical and practical way to save money. In other aspects, it is also necessary to find an experienced service organization. Because once any link in the process of obtaining experimental data fails, the funds paid to the laboratory cannot be recovered. With the help of agencies, enterprises can be targeted.
In addition, to save money, the months before the implementation of the new "measures" are crucial. If the enterprise starts the registration of new chemical substances before October 15, the whole process will still follow the requirements of the original "measures", and the whole process and experiment cost less. However, the new "measures" have much higher requirements for the registration of new substances, and the requirements for project requirements, data processing, chemical safety assessment technology and other aspects have been improved, and the cost of response will also increase.
Relevant departments have repeatedly reminded that after the implementation of the new "Measures", enterprises that produce, use or import new chemical substances need to obtain a registration certificate before they can operate normally. If you wait until October 15 to start collecting data and submitting applications, it will delay the business process of the enterprise. Therefore, if enterprises start early on the registration of new chemical substances, they can produce and sell them early, which still has a great advantage in occupying the market.
Undoubtedly, the registration fee of hundreds of thousands of yuan or even millions of yuan has deterred many domestic enterprises. In this regard, industry experts also put forward suggestions for enterprises to save registration costs.
Experts said that there are three categories in the new "Measures": regular, simple and scientific research filing declaration. According to the tonnage and use of new chemical substances, enterprises can choose different declaration types. For example, if the production or import volume is less than 1 ton, it can be carried out according to the basic situation of simple declaration. For the purpose of process research and development and the volume is less than 10 tons, simple special declaration can be considered, different types have different requirements in time and test data, and the corresponding costs are also very different. Enterprises must choose the correct type before preparing for registration to avoid unnecessary losses.
In view of the fact that new chemical substances are classified according to the List, and a large part of the new chemical substances that need to be registered in China have been registered in one or two foreign countries or regions at present, and the requirements for data in chemical registration in different countries are similar, therefore, enterprises can collect relevant test data abroad before registration, as long as the testing institutions have passed the certification and approval of relevant departments of their countries, most of them can also be used in the registration of new chemical substances in the country. This not only avoids repeated experiments, but also saves a lot of money for the enterprise. In addition, in the absence of commercial competition, the two enterprises can join together to register, which can also save a lot of costs.
Experts mentioned that in the new Measures, there is also a case of adding repeated declarations: that is, if two or more declarers declare the same new chemical substance successively, and the later declarer obtains the consent of the former declarer and uses the test data of the former declarer, the new chemical substance can be declared repeatedly. The method of sharing the cost of testing the data shall be agreed upon by the declarant. This is similar to REACH data sharing, but it may be difficult to operate in practice. After all, there is a greater chance of competition between enterprises registering the same substance. But if the two can communicate well, it is also a way to save money.
The main savings are still in the overall arrangement of animal experiments. Experts say, first of all, enterprises should not do all the items in the experimental project, because there is a correlation between chemical experiments. It should be done in stages, according to the first stage of the experiment to determine which experiments do not need to do. This is the most economical and practical way to save money. In other aspects, it is also necessary to find an experienced service organization. Because once any link in the process of obtaining experimental data fails, the funds paid to the laboratory cannot be recovered. With the help of agencies, enterprises can be targeted.