China Dangerous Chemical Registration
Dangerous Chemical Registration (or Hazardous Chemical Registration) has been being implemented for more than 10 years.
The first registration regulation was issued in September 2000, requiring China producers of hazardous chemical products to make registration.
The first regulation was revised 2 years later, further requiring users of hazardous chemical products and hyper toxic chemicals, as well as other units with meeting criteria of Critical Risk Sources 'GB18218-2009' to make the registration.
In July 2012, China State Administration Workplace Safety SAWS issued order No. 53 to issue a new Regulation on Hazardous Chemical Registration. Points of this new Regulation are as below,
1. China manufacturers and importers of Dangerous Chemicals should register the Dangerous chemicals listed in <Dangerous Chemical Category>. The Category was enacted in February 2015, replacing the 2002 version.
2. Newly established dangerous chemical Manufacturers should make the registration before the final acceptance of the plant construction.
3. Importers should make the registration before the first import.
4. If a Manufacturer produces and imports the same dangerous chemical, the manufacturer should make the registration as Manufacturer, and provide information of imported dangerous chemical.
5. If a chemical product (mixture, or preparation) is not covered by <Dangerous Chemical Category>, but ingredients of the product are covered and the total ratio of these covered ingredients are more than 70 w/w%, the chemical product should also be registered.
6. If hazardous properties of a chemical product is unclear, hazard identification and classification of the product should be made by accredited units. If the identification and classification result meets criteria of dangerous chemical as specified in <Dangerous Chemical Category>, registration for this product should also be made.
1). The Chinese manufacturer/importer (hereafter 'Registrant') submit Application through Registration System.
2). The local Registration Office generate account for the registrant in the system.
3). The Registrant fills in information (mainly information of SDS, as well Chinese GHS SDS and safety label) in the Registration System.
4). The local Registration Office examines the submitted materials. If the materials are good, then the local Registration Office submit the materials to National Registration Office NRCC for final examination.
5). When the materials also pass the examination by NRCC, then paper registration materials are submitted to local Registration office by Registrant.
6). Registration Certificate is issued to the Registrant.
(1). Registration Form.
(2). Business License copy of Manufacturer or Importer.
(3). SDS and Safety Label of the hazardous chemical products, which should fulfill China National standards.
(4). 24hr Emergency telephone number, which should fulfill the requirements.
(5). The hazardous chemical's quality specification (or standard code of corresponding China standards).
24hr Emergency telephone number requirement
*. Operate by full-time staff, 24hr on duty. The staff should be familiar with the hazard properties of their hazardous chemicals and with the corresponding emergency measures (emergency measures for fires/explosions/leakage/toxication /suffocation/burn during manufacture/usage/storage/transportation), should be able to response precisely.
*. If the hazardous chemical manufacturers should entrust the 24hr emergency consultation to Registration Offices if they are not able to provide the consultation by themselves.
*. Importers of hazardous chemical shall set up emergency consultation service by themselves or by entrusting to Registration Office, and imprint the 24hr emergency telephone number on safety label of imported hazardous chemicals.
Requirement of SDS and Safety Label
a. some physic-chemical properties are mandatory unless they meet the exemption condition: meting point, boiling point, vapor density, product density, explosion limit.
b. wordings and format of SDS and of safety label. The SDS and label shall be GHS version, in Simplified Chinese, and meeting China related standards e.g. GB/T 16483, GB 15258, GB/T 17519.
Remarkable points are that, SDS generated by software normally can not meet the requirement. And, due to capacity of staff in different local Registration Offices, a SDS examined good by one local Registration Office may fail in another local Registration (for example, a same hazardous chemical product is imported by different China importers in different provinces); and it is clear that exporters or manufacturers outside China can not make the registration.
The registration Certificate is valid for 3 years. Before expiration, the Certificate should be extended if the chemical business will continue. Same materials should be provided, especially revision of SDS is needed, as China requires that SDS shall be revised every 3 years.
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