The chemical regulatory affairs derived from the worldwide establishments of assorted chemical regulations that curb chemical trade between countries and regions, most notably the EU Reach, pose not only constraint, but also imperative on chemical manufacturers, exporters and downstream users to take keen eyes upon this global trend. Therefore, starting at June 1th this year, the SECN certainly arouses attention to all the chemical traders who’d wish to export their products into its market, which has been closed by the end of August, 2012. Its successful supplementation will promise certain chemical products to be traded much more freely into Taiwan market with much less restriction kindled by the emerging Taiwan NCN ( New Chemical Substance Notification). Here REACH24H is going to share the details of SECN by disclosing analyzing the case we have been through.

Document required.

Documents submitted are comprised of two parts: the Existing Supplementary Chemical Substances Nomination Tools in which information as follow have to be provided:

And the supporting documents that include the following:

In Addition, in the case REACH24H handled the documents submitted would have to consist of Invoice, SDS and the documents to recognize the identity of the applying company.

Applicants’ obligations. The applying company ought to provide the correct CAS No., the correct Chinese or English name of the substance. In order to better prepare the application, such as in this case while Reach24H—the third party is involved, the applying company are bound to be prompt in its communication with the latter, not only should it be ready for providing any supplement materials, but the supporting documents of product ingredients also.

Thorny points during the SECN procedures.

1. Substance naming. Let us take this case for instance. The applying company asked for 16 substances’ applications, which were all polymer or UVCB substances. In addition to the vacancy of CAS No., the English names the candidate provides too were erroneous. The experts from Reach24H, after probing further into corresponding regulations, formed the conclusion that most critical for the naming of substance was to follow the criteria of naming of monomer and polymerization mode. Thus, after cross-check the CAS No. and polymerization mode selected out from the English name given by the candidate finally confirmed the correct translation of these names on Chinese and English versions in accordance with the regulation, which resulted into the official pass for verification.

2.Relevant documents. The definitions of required documents are vague according to the official side and they do not refer to any specific documents must be included in certain categories. The initial documents which Reach24H helped to hand over include the Invoice and the SDS while the official suggestion later on also required the candidate to provide supporting documents for product ingredients, though without revealing any specific template. The submission of documents was finally sealed after Reach24H repeatedly inquired Taiwan enforcement authority with high efficiency upon drafting the supporting documents template totally from scratch.

Timeline for supplementation. Under normal condition, it takes only half a day for the filling in 5 substance information for supplementation, and after two days on mailing to Reach24h’s link in Taiwan, the official suggestion for verification will be arrived within 1-2 weeks.

From August 1th when the substance questionnaire was mailed to the receipt of notification letter of completion of supplementation on October 9^th, the total more than 2 months long. One distinct circumstance during this period is that the time Reach24H spent on the communication with the client and official side as well as the study of regulation is a lot more than filling in the submission reports.

The last time or there will be a next. Many companies may inquire whether this is the first and the last time for supplementation of substances. The answer is not clear. But one thing is for sure that anyone who has passed the supplementation this time will certainly enjoy less tight regulation on their products exporting into Taiwan market in the future.

What comes after successful supplementation? An active and volunteer attitude for the supplementation of product may help ensure the benefit of the company itself. The impending Taiwan New Chemical Substance Notification (very similar to that of the ‘China Reach’) has close relationship with this time’s supplementation. All substances imported into Taiwan market will later be searched in the inventory of existing chemical substances to decide whether they should go through the new substance notification or not.

This regulatory case reflects not only the chemical restriction is continuously tightening in Taiwan, but also reaffirms all the chemical traders around the world one simple fact that the wave of chemical regulation raging much more ferociously in a worldwide scale.

The competency in solving regulatory issues tells how Reach24H can serve the global clients to face and prepare for this regulatory setback. Like always, teamed with seasoned professional regulatory consultants, the China-based regulatory expert will continue its sturdy commitment for ‘Reach you in 24 hours’.

About Reach24H

REACH24H Consulting Group China, the member company of Centre Testing International Corporation, is the leading service provider for consultancy, scientific research, agency and technical support of chemical regulatory to various industries. Since 2009, our outstanding effectiveness, strictly-followed operation standards, confidentiality mechanisms have been working very well for either business leaders entitled with “Fortune Global 500” or small-and-medium enterprises throughout the world.

Sources:

• Any more information about Taiwan chemical regulatory updates, you may also visit official website for further details: http://csnn.cla.gov.tw/content/englishHome.aspx

• Existing Chemical Substance Inventory (draft) Information System
  http://csnn.cla.gov.tw/content/Substance_home.aspx