Oct 31st of 2012, Chinese official at the Open Seminar focusing on Chemicals Management Policies among China, Japan and Korea, answerred questions concerning MEP Order 22 ‘Environmental Management On Registration of Hazardous Chemicals’.
Q: according to Order 22, the existing hazardous chemical involved companies can enjoy a three-year grace period. Does it mean it is fine for these company to complete the registration before March 1st of 2016?
A: MEP will further specify the grace period for different types of comapnies involved.
Q: Order 22 requires an environmental risk assessment report. What is the guideline for the assessment report?
A: Companies shall entrust companies with good capability to prepare the assessment report. MEP is to release a particular technical guideline for that.
Q: When will the Catalogue of key Hazardous Chemicals for Environmental Management be released?
A: The Catalogue will be screened out from the Catalogue of Hazardous Chemicals, and should be published before the actual implementation of Order 22.
Q: What’s the difference between new chemical substances classifed as key hazardous substances for environmental management under MEP order No.7, and key Hazardous Chemicals for Environmental Management under MEP Order No.22?
A: New chemical substances classified as Key hazardous substance for environmental management under Order No. 7 will be merged into the Catalogue of key Hazardous Chemicals for Environmental Management under MEP Order No.22, after it is listed into the IECSC. Before that, the substance shall be managed according Order No. 7, and the chemical shall be evaluated by the Expert Evaluation Committee under MEP Order No. 7 to see whether it can be listed into IECSC or not at 6 months before the end of the 5th year as of its first date of manufacturing or import.
In other words, Order No. 22 regulates existing chemicals, which is different from Order No. 7 which regulates new chemicals.
Q: Shall newly established plants (including expansion and modification of exising plants) involved in hazardous chemicals complete the Registration as required by Order No. 22 before the plants to start (trial) production?
A: Yes. There would be some implementation guidelines to clarify these transitional issues soon.
Q: A plant involved in several hazardous chemicals will get one certificate or several certificate under Order No. 22?
A: One Ceritificate with all the hazardous substances listed on it.