Sunday, November 11, 2012

SAWS's Order 53 - The measures for the administration of registration of hazardous chemicals in China

11 July 2012, The final version of the measures for the administration of registration of hazardous chemicals was published by the State Administration of Work Safety(SAWS) via its order 53. The measures has set out the detailed requirements and procedures for registration as required by the regulations on safe management of hazardous chemicals (Decree 591) that came into force on 1 December last year. The new measures will replace those issued in 2002 and enter into force on 1 August 2012.


The key principle is that manufacturers and importers in China shall register hazardous chemicals with the National Registration Center of Chemicals (NRCC) of SAWS prior to manufacturing or importation. The validity of registration certificate is 3 years and has to be renewed 3 months prior to the certificates expiry date.

The measures will trigger important new obligations for companies, especially importers in China because importers are not required to register under old measures.

The Scope of Hazardous Chemicals Subject to Registration

The following two types of hazardous chemicals are subject to registration:
  • Chemicals listed in the Catalog of Hazardous Chemicals; 
  • Chemicals which are not listed in the Catalog but are identified as hazardous by designed institutions; 

Eventually all chemicals(substances or mixtures) classified as hazardous according to GHS (excluding certain hazard categories such as acute toxicity 5) will require registration.
Documents Required for HazChem Registrations

Unlike new chemical registration which requires expensive toxicology data, eco-toxicology data and risk assessment, HazChem registration only requires the following information:
  • legal entity information 
  • classification and labeling 
  • physiochemical properties 
  • main uses 
  • hazard classes 
  • conditions for safe storage, use and transport 
  • emergency responses. 

SAWS's Order 53 - The measures for the administration of registration of hazardous chemicals in China

Thursday, November 1, 2012

The Measures for Environmental Administration Registration of Hazardous Chemicals 2012 - MEP Order 22

17 Oct 2012, The Chinese Ministry of Environmental Protection has released the trial Measures (MEP’s order No. 22) for Environmental Administration Registration of Hazardous Chemicals. This new measures will enter into force on 1st March 2013. This regulation is also one of the supporting measures of Regulations on Safe Management of Hazardous Chemicals (Decree 591) in China.

There are two requirements in the new measures:
  • Manufacturers of hazardous chemicals and companies who use hazardous chemicals to manufacture products shall submit an environmental administration registration to environmental protection authorities. Only chemicals listed in the Catalog of Hazardous Chemicals will be affected. Those hazardous chemicals will be further classified into two categories: general hazardous chemicals and priority hazardous chemicals for environmental management (PHCs). There are more stringent requirements for the registration of PHCs. 
  • Companies which deal with import and/or export of chemicals on the “List of toxic chemicals severely restricted to be imported into or exported from the People Republic of China” need to register with the Chemical Registration Centre (CRC) of MEP and apply for relevant registration certificates or custom clearance notification. 

Registration of General Hazardous Chemicals and PHCs

For general hazardous chemicals, manufacturers and companies who use hazardous chemicals to manufacture products in China shall submit an environmental administration registration to local environmental protection authorities at county level and obtain a registration certificate issued by environmental protection authorities at city level(article 6), which is then valid for 3 years. The registration needs to be submitted prior to the issue of acceptance statement for newly built or enlarged project.


The following documents are required for registration (article 9):

  • Environment administration registration form including legal entity information, the names of hazardous chemicals, volume, uses, operational method, safety data sheet, environmental risk management measures, transfer of waste and disposal of hazardous waste; 
  • Result of environmental impact assessment; 
  • Environment emergency response plans; 
  • Environment monitoring report. 

For PHCs, companies shall entrust qualified institutions to prepare an environmental risk assessment report and submit this report to authorities in addition to above required materials when applying for a registration certificate (article 10). The registration certificate for PHCs will be issued by environmental protection authorities at provincial level.


Companies who have manufactured hazardous chemicals or have used hazardous chemicals to manufacture products before the new measures enter into force must submit environmental administration registration within 3 years since the date of entry into force.

Priority Hazardous Chemicals for Environmental Management (PHCs)

The list of priority hazardous chemicals for environmental management will be promulgated and updated by MEP (Article 11). Even though the new measures have not specified which chemicals might be added to the list of PHCs, chemicals meeting either one of the following criteria may be added to the list according to the draft measures published last year.
  • chemicals that are not easily degradable, bio-accumulative and can cause serious harm to human health and living beings after long-term exposure; 
  • chemicals that are extremely un-degradable and extremely bio-accumulative; 
  • chemicals that can cause acute toxicity or chronic toxicity to aquatic environment; 
  • chemicals that can serious hazards to human health or the environment; 
  • chemicals subject to any international environment conventions; 
  • chemicals liable to accidents and causing severe hazards to the ecological environment; 
  • other chemicals for which risks need to be reduced; 

In addition to environmental administration registration, companies have obtained registration certificates need to fulfill the following obligations:
  • Submit pollutant release & transfer form and environmental risk management plans to environmental protection authorities at county level before 31st Jan of each calendar year; 
  • Publish annual hazardous chemical environmental administration report including the names of hazardous chemicals, hazard properties, waste & accident information and disposal measures for waste, and make this report available to the public; 
  • Keep a file regarding hazardous chemicals manufactured or used such as type, volume, flow, waste discharge and environmental monitoring information on a long-term basis; 
  • For PHCs, companies shall carry out environment monitoring of hazardous chemicals and waste; 


More info can be found here.
China MEP Order 22 - the Measures for Environmental Administration Registration of Hazardous Chemicals 2012