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While the industry is looking forward to the draft revision of Order No. 7, the Ministry of Ecology and Environment has released the good news of the Notice on Supplementing and Perfecting the Inventory of Existing Chemical Substances in China (Document No. 575 of the Office,2019).As is known, the Inventory of Existing Chemical Substances in China (Hereinafter referred to as "IECSC”) is used to distinguish between existing and new chemicals.
According to Articles 3 and 5 of Order No. 7, chemical substances not included in the List are regarded as new chemical substances. Producers or importers of new chemical substances must obtain registration certificates before production or import.
Currently, the published one is IECSC of 2013 edition, issued as Announcement No.1 of 2013 by the former Department of Pollution Prevention of the Ministry of Environmental Protection. The IECSC contains 45612 chemicals, including the Chinese and English names, molecular formulas, and American Chemical Abstract Number (CAS) or Serial Number.
The development history of IECSC is as follows:
List of Existing Chemicals Produced or Imported in China is the predecessor of IECSC, which contains "Chemicals Produced, Processed, Sold, Used or Imported in China for Commercial Purposes from January 1, 1992 to October 15, 2003".After the implementation of Order No. 17 issued by the former State Environmental Protection Administration (SEPA), the List came into being and was updated dynamically according to the progress of new chemical substances.
| 1 | Core List of 1995 Edition | Compilation of Core List in 1995 | N/A |
| 2 | Official edition of List | First Supplement 1996-1997 | N/A |
| 3 | IECSC 2000 | Second Supplement 1999-2000 | 26707 chemicals were collected. |
| 4 | IECSC 2002 | Third Supplement 2001-2002 | N/A |
| 5 | IECSC 2003 | Fourth Supplement 2003 | N/A |
| 6 | IECSC 2004 | Fifth Supplement 2003-2004 | N/A |
| 7 | IECSC 2005 | Included by SEPA on a case-by-case basis from 2004 to 2005 | The total number of substances was 44922, of which 2986 were identified as confidential substances. |
| 8 | IECSC 2007 | From 2006 to the end of August 2007, according to the requirements of SEPA Document 12, all material information included. | The total number of substances was 45018, of which 2994 were identified as confidential substances. |
| 9 | IECSC 2008 | From 2007 to the end of December 2008, according to the requirements of SEPA Document 12, all material information and structural pictures of substances with CAS numbers included. | The total number of substances was 45290, of which 3080 were identified as confidential substances. |
| 10 | IECSC 2009 | From 2008 to the end of October 2009, according to the requirements of SEPA Document 12, all material information and structural pictures of substances with CAS numbers included. | In IECSC 2009, the total number of substances was 45355. |
| 11 | IECSC 2010 | From 2009 to the end of October 2010, all material information and structural pictures of substances with CAS numbers included. | In IECSC 2010, the total number of substances was 45602, of which 3166 were identified as confidential substances. |
| 12 | IECSC 2013 | In IECSC 2013, the total number of substances was 45612, of which 3270 were identified as confidential substances. |
In the IECSC of 2013 edition, the substances were sorted out based on the 2010 edition, such as deleting duplicate substances; in addition, the number of confidential substances increased by 104, the number of non-confidential substances decreased by 94, and the total number of substances increased by 10.
From the above history, it can be seen that from the starting in 1995 to the suspension in 2011, IECSC listing has been an important part of the work of the inventory. On November 18, 2011, supplement of the IECSC was suspended because of the Notice on the Procedure for the Listing into IECSC of Chemicals Produced or Imported in China before the Measures for the Environmental Management of New Chemicals came into force, issued by the former Ministry of Environmental Protection.
The relevant contents of the restarted IECSC Listing are described below:
Article 42 of Order No. 7 [Regular Investigation] clearly states that the Ministry of Environmental Protection organizes a survey of new chemical substances every five years, and that the Ministry of Environmental Protection conducts the listing of chemicals legally produced or imported in the territory of the People's Republic of China before October 15, 2003. The former Ministry of Environmental Protection collected some chemicals with definite identifications but not included in the IECSC in the surveys in 2014 and 2016. In response to the appeal of enterprises in recent years, the Ministry of Ecology and Environment restarted the work of IECSC listing after the suspension of eight years from 2011.
The supplementary substances are the ones which have been legally produced or imported in the territory of the People's Republic of China before October 15, 2003 and have not been included in the IECSC. Manufacturers, importers, users and associations can all submit applications as applicants. The application materials include application forms and related certification materials. The certification materials mainly include distribution invoices, import and export declarations, industry statistics, chemical yearbooks, documents issued by administrative departments, public publications and other materials that can prove that chemical substances were legally produced or imported in the territory of the People's Republic of China before October 15, 2003.
On the one hand, applicants need to prove the legality of the production or importation of chemicals before October 15, 2003. On the other hand, they need to provide relevant supporting information. The form requirements of application materials are simple, and the scope of proof materials can be used is very wide, but because of the long time, the requirement of enterprise data storage is very high. Many foreign-funded enterprises will find the original documents sixteen years ago more difficult due to the merger and dismantlement in recent years. We can consider looking up more relevant proof materials from the industry's public information.
Finally, we would like to remind you that the deadline for submission of materials is September 30, 2019. Enterprises that need to apply for IECSC listing should submit relevant materials to MEESCC within the deadline.
Welcome to contact us for any details or any specific cases.
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