On January 5, 2022, the Work Safety Committee of the State Council issued the National Plan for Centralized Management of Safety Risks of Hazardous Chemicals^[1]. The plan proposes to enhance the digital and intelligent management of hazardous chemicals. The Emergency Management Department shall be responsible for promoting the upgrading of chemical registration system.  “One enterprise, one chemical product, and one QR code” management shall be imposed to achieve efficient hazardous chemical information transfer through the whole life cycle.

The existing online registration system was launched by NRCC, the National Registration Center for Chemicals in July of 2013. In July, 2021, NRCC upgraded its registration platform and piloted it in Guangdong Province. Under the new system, there are some new requirements in applicants and obligations.

More enterprises, in addition to Hazchem manufacturers and importers (obliged for Hazchem registration, same as before), will be covered to report Hazchem information, including the operators that have obtained Hazchem safe operation license, the users that have obtained Hazchem safe use license and the chemical and pharmaceutical enterprises defined according to GB/T 4754-2017. However, they are only required to submit simplified info online, which is not the same thing of Hazchem registration. The data only need to be reviewed by local management department at district/county/city level and the provincial registration office. NRCC will not be involved for review work and no certificate will be issued.

Based on “one enterprise, one chemical product, and one QR code” principle, the system incorporates a new function on QR codes generation for each substance or mixture registered in China. It allows manufacturers or importers to generate QR code online automatically after accomplishing Hazchem registration and obtaining registration number. For enterprises that only operate or use hazardous chemicals, or other chemical and pharmaceutical industries, no QR code will be assigned to (Chemlinked news)^[2].

According to insiders from NRCC, an agent system^[3] is on the agenda for discussion. In the future, to avoid multiple QR codes generated for the same chemical that is produced by the same foreign manufacturer while imported by different importers, the foreign manufacturer may be allowed to designate a Hazchem manufacturer/importer registered in China as the agent to jointly fulfill the QR code obligation and take responsibility according to law.

In addition, relevant laws and regulations will be formulated and revised to promote the management of the new system. For example, Article 10 has been added in the Law of the People’s Republic of China on Safety of Hazardous Chemicals (Draft), which stipulates that the Ministry of Industry and Information Technology of the State Council, in conjunction with relevant departments of the State Council, establish a hazardous chemicals information management system, and implement electronic identification and whole life cycle information management of hazardous chemicals. The Regulations on the Administration of Hazardous Chemical Safety Information Codes (Trial) has been drafted for comments, waiting to be released in the near future. The revision plan of GB 15258 General Rules for Preparation of Precautionary Label for Chemicals also has been submitted to further standardize the pasting requirements of QR codes.

Enterprises need to keep an eye on the notices from NRCC, as some provincial registration centers have already prepared for the launch of the new system. Enterprises have been asked to fill out hazardous chemicals management files and questionnaires. They have been urged to complete the registration of hazardous chemicals or cancel the account as soon as possible before February, so as to avoid any delay in compliance due to data migration.

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