On 16 January 2019, Taiwan amended the country’s toxic chemical law from Toxic Chemical Substance Control Act (TCSCA) and renamed it to Toxic and Concerned Chemical Substance Control Act (TCCSCA). On March 11, 2019, Taiwan’s Environmental Protection Administration (EPA) published the amended Regulation on New and Existing Chemical Substances. From 1 January 2020, manufacturers or importers who manufacture or import any Existing Chemical Substance in an annual amount of 100 kilograms or more, should apply for the Phase One Registration within 6 months from the date of manufacturing/importing. Taiwan’s EPA also published a list of 106 Priority existing chemical substances (PECs) subjected to standard registration.
For New Chemical Substances, manufacturers or importers should register chemical substances 90 days prior to manufacture or import.
Non-Taiwanese manufacturers not willing to disclose their product information to their Taiwanese clients (Importers) can ask the importers to nominate a Representative to fulfil their compliance and annual reporting obligations.
GPC Taiwan can support you to comply with TCCSCA as a Third Party Representative (TPR), including preparing Phase One Registration, Standard Registration (106 PECs), new substance registration and annual reporting.
Information items for Phase One Registration
Information items for Standard Registration (106 PECs)
The EPA showed its intention to grant the extension of the deadline for Standard Registration of 106 PECs as chemical manufacturing and import associations in Taiwan raised their concerns over the preparation for dossiers in public seminars in October this year. Now the EPA has confirmed to extend the deadline of Standard Registration to Dec. 31, 2020, regardless of the tonnage.
Currently, registrants can get the registration number of Standard Registration even if they have not submitted hazard and exposure assessment (Item 8 and 9 in dossier report). The date for later submission of these two items will be clarified later when the guidance is updated.
According to the amended Toxic and Concerned Chemical Substance Control Act, Taiwan’s EPA has to regularly review its fee scheme.
According to the proposed revision on “the Toxic Chemical Substances Handling Application and Chemical Substances Registration Fee Scheme” in September 2020, 25 % discount on the review fee is proposed for SMEs with additional discount possibilities if companies adopt alternative testing methods or submit their PECs registration one year ahead of the deadline.
At the public meetings, the EPA highlighted that registrants may submit the registration dossier without hazard and exposure assessments and the revised guideline for PEC standard registration may expand to multi-source data.
With 60 days for public comments, the EPA is expected to announce a new fee scheme and PECs registration deadlines.
Companies should expect longer time for dossier preparation and back-and-forth conversation within the supply chain. It is also important to note that join-registration is not mandatory. Contact GPC ([email protected]) to prepare your dossier now and gain lead time.