On June 21, 2019, the Ministry of Ecology and Environment (MEE, formerly the Ministry of Environmental Protection (MEP)) issued a notice on supplementing and improving the Inventory of Existing Chemical Substances in China (IECSC). Per the notice, chemical substances that were legally produced or imported in China before October 15, 2003, but that are not on the IECSC, except for the substance categories exempted from the “Environmental Management of New Chemical Substances” (MEP Order No. 7), could be added to the IECSC. Applications for the addition of chemical substances to the IECSC should be submitted before September 30, 2019.

Manufacturers, importers, users, and relevant trade associations/institutions can submit the application with relevant supporting documents to the MEE before September 30, 2019. The relevant supporting documents include invoices, customs declarations, industrial statistical reports, chemical industrial yearbooks, government issued documents, publications, and other evidence that the chemical substances were legally produced or imported in China before October 15, 2003.

MEE will organize experts to review the applications, post the review results on the MEE website for ten working days, and, if there are no objections from the public, add the substances to the IECSC.

Substances that are not listed on the IECSC must be registered as new chemical substances according to MEP Order No. 7 and cannot be produced, imported, or used without a new chemical substance registration. MEE will enhance the enforcement of illegally produced, imported, or used new chemical substances.

Commentary

China is witnessing renewed interest in the enforcement of environmental regulations and chemical safety. The recent high profile accidents and explosions, including the chemical explosion at Jiangsu Xiangshui Chemical Industrial Park, prompted governmental inspections, closing thousands of facilities, including the permanent closure of Jiangsu Xiangshui Chemical Industrial Park, and revisions to safety law. This notice is intended to enhance the enforcement of new chemical substance registrations. Importantly, it is also an opportunity for companies to nominate their substances for inclusion in the IECSC since the last opportunity in 2011.