CRC-MEP issued on November 8th of 2012 at its website the 2nd Questions & Answers for New Chemical Substances Management. These Q&A include,

 

89. Q: Are materials extracted by water steam from vegetation exempted from the registration requirement?

A: No.

 

 

90. Q: A substance is not listed in IECSC, while its salts e.g. potassium salt is listed in IECSC. Can the test data of its salts be used for the registration of the substance?

 A: No.

 

 

91. Q: Several Registrants outside China plan to make registration of a same substance (joint registration). Do these Registrants need to appoint a same Notification Agent?

A: These Registrants can appoint different Notification Agents.

 

 

92. Q: Does Serial Registration (registration of a Series new chemical substances with similar structure, function, properties) need to provide full set of test reports of at least one substance?

A: Toxicity and eco-toxicity tests can be from different substances in the Series, but each substance should provide its own full set of physi-chemical test reports as required by the Guideline. 

 

 

93. Q: Can Serial Registration use test data of a chemical substance which is not in the Series of substances?

A: Can not.

 

 

94. Q: What is the difference between Repeated Registration and Data provided by 3rd party?

A: Repeated Registration means a latter Registrant makes registration by using data owned by previous Registrants. Both the latter Registrant and the previous Registrants will be issued Registration Certificate after the registration is approved.

 

Company providing data as 3rd party will not get Registration Certificate after the registration is approved. And, if the data from the 3rd party were ever used for Typical Registration, then total registration quantity will be calculated for the new registration.

 

 

95. Q: Company A made a Typical Registration for 900 tons (Level 3). If Company B makes Typical Registration of 900 tons for the same substances, will Company B be required to provide test data for total quantity of 1800 tons (Level 4)?

A: If Company B uses even one test report provided by Company A, then yes, otherwise not. 

 

 

96. Q: If Company A made Typical Registration of a substance under Order 17 (the old Provisions), now Company B makes Typical Registration of the same substance under Order 7 (the revised Provisions), will Company B be required to provide test data based on the total registration quantity?

A: No. 

 

 

97. omitted by Randis. 

 

 

98. For Level 2 Typical Registration (10~100ton), if 14-day fish toxicity test report is made, can acute fish toxicity test be exempted?

A: can not. 

 

 

99 Q: X Substance was registered by company A outside China, then X is imported to Company B inside China. When Company B exports X to outside China as component of a mixture, does Company B need to make registration?

A: No. 

 

 

100 Q: X Substance was registered by company A outside China, then X is sold to Company B outside China. When Company B exports X to China Customer C, does Company C need to make registration?

A: Yes, Company B or Company C needs to make registration.

 

101. Q: Company A made registration for substance X. If Company A does not produce/import X in following 2 years, does Company A need to withdraw the registration Certificate?
A: It is upto the company to decide whether to withdraw the Certificate. If the company withdraws the Certificate, then the company is not allowed to make the registration for substance X again within 5 years.  

 

 

102. Q: Company A made Record Notification of substance X, then provides the substance X to Company B for Scientific Research. While Company B sells the substance X for normal business purpose (not for Scientific Research purpose). In such situation, which company takes the liability?

A: If Company A already carries out the responsibilities as defined in the Provisions Order 7, then Company A does not take liability for that. Otherwise both Company A and Company B take the liability. 

 

103. Q: Company A is making Simplified Registration for polymer X. Then Company A want to enlarge the registration quantity and the usage of polymer X. How sould Company A do?

A: If the registration is not approved yet, then Company A can cancel the registration and submit a new registration. If the registration Certificate is issued already, then Company A should submit a new registration, and return the issued Certificate back to CRC.