Re-inquiry Recommended to Confirm the Status of Your New Chemical Substance
The Inventory of Existing Chemical Substances (IECSC) in China serves as the basis to judge whether a substance is identified as a new chemical substance, which is subject to China new chemical substance notification (China NCSN). However, the IECSC is managed in a dynamic way. As the latest version of IECSC 2013 has been released and some substances have been added into the inventory, it is recommended to re-apply for an IECSC comprehensive search to verify the substance of your concern is still deemed as new chemical substance to avoid unnecessary registration work. With more substances added to the IECSC in 2013, it will afford some companies exemption from the costly and time-consuming China NCSN procedure. However, it creates the possibility of wasted efforts in preparing notification documents if substance becomes included in the IECSC unnoticed. Several such cases have been reported from the industry. However, the CRC-MEP has no corresponding solutions to this issue. To compile the IECSC 2013, besides the inclusion of some substances into the inventory, the experts have modified around 1246 entries of information and deleted some repeated entries from the IECSC 2010. According to the CRC-MEP, the companies making formal inquiry in December 2012 can rest assured since the inquiry result will not be affected due to the update of the IECSC, while it does not apply for other cases. The conservative approach is to make another comprehensive inquiry with the CRC-MEP to re-confirm the substance status. The new chemical substances notified under the MEP Order 17 will be gradually included into the IECSC when the relevant guidance documents are ready. Besides, as 2015 is approaching, the new chemical substance granted certification of regular notification under the MEP Order 7 will also have the chance to be added into the IECSC. To expedite the IECSC inclusion procedure of qualified new substances and to avoid the unnecessary notification resulting from the IECSC update are the two urgent tasks to be tackled by the CRC-MEP in the near future.