Overview of Hazardous Chemicals Registration in China

China

Overview of Hazardous Chemicals Registration in China

Little Pro on 2018-07-11

In China, both new chemical substances and hazardous chemicals require registrations prior to manufacture or importation. New substance registration is similar to EU REACH registration or TSCA pre-manufacture notice (PMN). Many people are only familiar with new substance notification (China REACH) but not with hazardous chemicals registration. In this article, we will try to give you an overview of hazardous chemicals registration in China. We will focus on its legal basis, procedure and info requirements.

Legal Basis

The article 66 and 67 of State Council Regulations on Safe Management of Hazardous Chemicals requires that domestic manufacturers and importers of hazardous chemicals register hazardous chemicals with chemical registration offices affiliated with State Administration of Work Safety (SAWS) prior to manufacturing or importation. Detailed registration requirements and procedure are outlined in SAWS's order 53 - The Measures for the Administration of Registration of Hazardous Chemicals.

The main purpose of HazChem registration is to inform authorities of the type of hazardous chemicals which a company deals with in China.

Note:

SAWS has been renamed as the Ministry of Emergency Management (MEM) in 2018
Foreign companies cannot submit hazardous chemicals registrations
There is no small volume exemption

Hazardous Chemicals Subject to Registration

Hazardous chemicals include both hazardous substances and hazardous mixtures. A product (substance or mixture) requires hazardous chemicals registration if:

It is listed in the Catalog of Hazardous Chemicals; or;
It is not listed but identified as hazardous based on available data;

To be more specific, chemical products classified with the following GHS hazard categories [GHS classification criteria] will require registrations.The criterion is defined in the Catalogue of Hazardous Chemicals (2015).

Explosives: unstable explosives, 1.1, 1.2, 1.3, 1.4
Flammable gases: category 1, category 2, unstable gases A, unstable gases B
Aersols: category 1
Oxidising gases: catagory 1
Gases under pressure: all 4 types
Flammable liquids: category 1, 2, 3
Flammable solids: category 1, 2
Self-reactive substances: A, B, C, D, E,
Pyrophoric solids: category 1
Pyrophoric liquids: category 1
Self-heating substances and mixtures: category 1, 2
Substances which on contact with water emit flammable gases: category 1, 2, 3
Oxidising liquids: category 1, 2, 3
Oxidising solids: category 1, 2, 3
Organic peroxides: Type A, B, C, D, E, F
Corrosive to metals: category 1
Acute toxicity: category 1, 2, 3
Skin irritation/corrosion: category 1A, 1B, 1C, 2
Eye irritation/serious eye damage: category 1, 2A, 2B
Respiratory or skin sensitizer: 1A or 1B
Germ cell mutagenicity: category 1A, 1B or 2
Carcinogenicity: category 1A, 1B or 2
Reproductive toxicity: category 1A, 1B, 2 or additional category
Specific target organ toxicity - single exposure: category 1, 2, 3
Specific target organ toxicity - repeated exposure: category 1, 2
Aspiration hazard: category 1
Acute hazard to aquatic environment: category 1, 2
Chronic hazard to aquatic environment: category 1, 2, 3
Hazardous to the Ozone layer: category 1

Note: For a chemical product with unknown physical hazards (i.e, a chemical outside of the Catalog), hazard identification needs to be conducted by qualified institutes as required by SAWS’s order 60 for physic-chemical identification and classification. If the product is identified as hazardous, a registration will be required.

Registration Procedure and Information Requirement

The following info for each hazardous chemical product needs to be submitted online to provincial HazChem registration office which conducts preliminary review and passes complete registration materials to the National Registration Center for Chemicals (NRCC) of SAWS based in Qingdao City. The whole process takes about 2 months.

Legal entity information;
Classification and labeling(China GHS);
Phyiso-chemical properties (i.e, flash point, melting point);
Main uses;
Hazard properties;
Safety requirement for storage, use and transport;
Emergency responses(24h emergency contact number required);
Chinese GHS SDS and labels - mandatory.

Registration certificate is valid for 3 years and can be renewed be renewed 3 months prior to certificate’s expiry date. Attached picture is an example of hazardous chemicals registration certificate. The registration certificate lists all hazardous chemicals registered by the registrant.

China Hazardous Chemicals Registration

To access the online registration system, please click the following link. New user needs to be verified by provincial HazChem registration office prior to using the online registration system.

https://register.nrcc.com.cn/EnterpriseManage/Login.aspx;

The picture below is the main window after login.

Frequently Asked Questions

Q1. My company not only produces a hazardous chemical product but also imports the same hazardous chemical product. Shall we register the product as a producer or importer?

A: You only need to register the hazardous chemical product once as a producer.

Q2. My company produces a series of hazardous chemical products with similar composition and the same GHS classification. Do we need to register each product separately?

A: No. You can register them as one product. You need to indicate the concentration range of hazardous ingredients.

Q3. What is the requirement for 24h emergency telephone number?

A: It must be a domestic 24h emergency telephone number. Both domestic importers and foreign manufacturers can provide this number for HazChem registration use.

Q4. How to provide product standard info?

A: If there is national or industry standard available, you can provide standard no. If not, you need to provide the full text of your own enterprise standard.

Q5. Do we have to register intermediate products?

A: Yes if such intermediate products belong to hazardous chemicals.

Q6. Could we submit our own GHS classification?

A: For chemicals listed in the Catalogue of Hazardous Chemicals, you must use mandatory classification. For other hazardous chemicals, self-classification is accepted.

Q7. How we provide physio-chemical data source?

A: You must provide physio-chemical data (such as flash point) and data source. Data source could be authoritative database, literature or your own test report.

References

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