Effective 1 January 2005 the regulations concerning registration of chemicals in China have changed
The State Environmental Protection Administration Chemical Registration Center (CRC) announced on 14 November 2004 that all chemicals manufactured or imported into China prior to 14 October 2003, but not yet included in China's Inventory of Existing Chemical Substances in China (IESCS) must have submitted an application to be included in the IESCS before 30 December 2004. Chemicals not included in the updated IESCS are considered New Chemicals

New Chemicals Registration
In accordance with the Provisions on the Environmental Administration of New Chemical Substances, New Chemicals must be approved by the CRC if they are not included on the IESCS by 30 December 2004.

According to the provisions a New Chemical applicant must submit to CRC a dossier for formal technical review, including:

• Extensive physical data
• Toxicity
• Eco-toxicity testing

(The regulation specifies that certain tests must be performed in China).
More information can be found by visiting http://www.crc-sepa.org.cn

Chemical ingredients for cosmetics
Finished cosmetic products are regulated by the Ministry of Health and are excluded from the November 1, 2004 CRC announcement.  Chemical ingredients manufactured or imported into China that will be used in the manufacture of cosmetics however must be included in the IESCS or be approved as New Chemicals after December 30, 2004.

Penalty for non-compliance
After January 1, 2005 companies using chemicals not listed in the IESCS will be deemed to be in non-compliance to the law and could be subject to a fine and, more significantly, a 3 years embargo on being allowed to import any New Chemicals.

Ciba have extensive experience in advising customers on changes to regulations concerning chemical substances. Below are the latest Bulletins that have been issued.

Ciba Regulatory Services Bulletin (pdf, 112 KB) New Chemical Laws in China, effective 1 January 2005, require companies to register all chemical substances on the Inventory of Existing Substances If you would like to receive future bulletins please send an email to Sybille Wälchli and specify topics you would like to receive