There had been several ways of listing chemical substances to China IECSC,

1. through supplementation application,

2. through typical notification,

3. throuh inspection by EPA.

Method 1 was the most cost-efficient way: if the chemical was ever in China before Octobr 15th of 2003 and evidence could be shown, the company could make application to Ministry of Environmental Protection to supplement the chemical to IECSC.

While this method was ceased by the Ministry on November 18th of 2011.

Method 2 is the formal way to list a chemical substance to IECSC, while it takes time and costs a lot.

Method 3 is a way as described in the revised Provisions (Order 7). Item 42 of Order 7 says 'the Ministry will organize investigation and inspection on New Chemical Substances every 5 year. For chemicals that have been legally manufactured or imported within territory of the People’s Republic of China before October 15, 2003, MEP will list them into IECSC'.

While the detailed pross for this operation is not clear yet, and there are some questions on this point.

For further information, please feel free to contact us.