With the advancement of technology and the gradual resolution of the traditional environmental problems, environmental and health issues caused by chemicals become the focus of international attention and chemicals management has also become the key issue of the world’s environment and health management.

China is one of the world’s largest exporters. Foreign trade has become an important driver of China’s GDP growth. However, in recent years the issue that developed countries’ increasingly stringent implementation of “Technical Barriers to Trade (TBT)” prevents or restricts the export of Chinese products has become more and more obvious, in particular the “green barriers” caused by chemical residues. Here, we have to admit that this phenomenon has a great relationship with China’s existing chemicals environmental management which is relatively weak. Although we has also made some efforts towards existing chemicals environmental management, the chemicals environmental management system cannot meet the requirements of environmental protection and public health and safety, which is mainly reflected as: (1) National chemicals environmental management policy and strategies are still not clear; (2) Regulations are incomplete; (3) Lack of institutional capacity and inadequate law enforcement; (4) Lack of public participation; (5) Management support system is imperfect and integrated management measures are inadequate. Of course, another aspect is that we have a lack of professional third-party regulation service agencies.

Based on above issues, our future efforts need to focus on the following points:

Firstly, change of the concept of administration government: (1) environmental protection oriented economic growth; (2) change the situation of “treatment after pollution; treatment and destruction simultaneously”; (3) comprehensive use of laws, economics, technologies and necessary administrative measures to solve environmental problems.

Secondly, we can learn from some developed countries about the chemicals environmental management systems, such as new chemical substances notification system; existing substance risk assessment and risk management systems.

For  those  substances mentioned  above,  it will be required a simplified notification or scientific  research  record  notification under revised CHINA REACH.

For Non-CN manufacturers, they can only submit  the  notification  by  their  Chinese legal   ent i ty  or   appoint   an  “Only Representative” in China.We will  continue  to monitor  the  situation closely  and  will  provide  further  guidance on how to make notification in near future.