Substance Registration in China: Why Companies Must Be Liable in the Future

In the future, companies that want to register a new substance in China must comply with the newly revised chemicals law, MEP Order 7, and present a Letter of Commitment. The document attests to their legal liability should the chemical cause any sort of damage. The document has two essential functions. First, it lists risk-control measures for the chemical and the requirements for environmental management. Second, it states the company’s liability for the authenticity, completeness, exactitude, and validity of the new substance dossier.

A company must submit a supplemental Letter of Commitment when it wants to use a chemical in a manner that differs from that defined in the registration dossiers. In such a case, a new registration is also required.

As part of the Asia Summit in Kuala Lumpur sponsored by Chemical Watch, Lisa Xu, a consultant from CIRS China, warned companies to select the test laboratories they work with critically. She noted that test reports will be checked more closely and the penalties for violations will be higher. Fines of more than US$4,000 are possible. In the event of a transgression, a registration application would not be accepted for a year, and certificates that have already been issued would be revoked.

The current version of MEP Order 7 will take effect next year.

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