China is now actively promoting the implementation of “one enterprise, one chemical product with one code” rule for hazardous chemicals, under which a unique QR code will be automatically generated through the new online system for hazardous chemicals registrations - the Comprehensive Service System for Registration of Hazardous Chemicals. The QR code must be included in the label. However, since the launching of the Comprehensive Service System for Registration of Hazardous Chemicals on February 16 2022, enterprises have encountered numerous problems. In order to help enterprises better adapt to the new system, CIRS has collected the frequently asked questions regarding the new system and the “one enterprise, one chemical product with one code” rule.
1. Are there any updates and changes in the scope of registration and registration categories?
Under the previous system
- The types of businesses cover: Manufacturers, distributors and users of imported hazardous chemicals;
- The registration categories cover: chemical products, intermediate products, imported chemicals, raw materials;
Under the new system
- The types of business cover: Manufacturers, importers, operators, and users (use license obtained) of hazardous chemicals, chemical industry enterprises (use license not obtained), pharmaceutical enterprises, as well as other types of enterprises.
- The registration categories cover: Chemical products, intermediate products, imported chemicals, raw materials, operating chemicals, etc.
2. What are the criteria that chemicals need to meet to be listed in the Catalog of Hazardous Chemicals (2015)?
- Chemicals that are listed in the Catalog of Hazardous Chemicals (2015) and Implementing Guidance;
- Chemicals that meet the flash point determination rule in No.2828 of Catalog;
- Mixtures whose main constituents are all listed as hazardous chemicals in Catalog, and the total mass or volume percentage of main constituents is not less than 70% (except for those chemicals identified and excluded from hazardous chemicals according to “Determination Principals for Hazardous Chemicals”);
- Inorganic salts (both anhydrous and crystalline compounds included) that are listed in the Catalog;
3. What are the requirements for the filling of category name during registration?
- For chemicals listed in the Catalog of Hazardous Chemicals (2015), related enterprises should better choose the recommended category name in the Catalog;
- When registering substances or mixtures that are not listed in the Catalog, pure English letters or numbers are not allowed to fill in. Since the registered names stand for its chemical characteristics, brief descriptions on chemical functions attached with an identification code are available;
- Special symbols or character strings shall be avoided;
- Collection entry name (synthetic resins containing flammable solvent, auxiliary materials, paints and other products [closed flash point no more than 60℃]) of No. 2828 in the Catalog shall not be filled in while specific product name needs to be filled in instead;
- CAS numbers of pure substances and some particular mixtures (such as gasoline, natural gas, etc.) are required to be filled in while other mixtures are not.
4. I have had an account under the previous system, do I need to open a new account under the new one?
You can log in the new system with your existing account. But you need to reset your password after login.
5. Can I withdraw or modify the request for change if mistakes happen during the change of registrations?
No, you cannot withdraw or modify the request for change. Therefore, all items shall be fully considered when applying for change of registration. Once a mistake happens, you can only make another application after whole procedure is completed.
6. When will “one enterprise, one chemical product with one QR code” rule be implemented in a mandatory manner?
Currently, it is not mandatory nationwide and the specific implementation plan will be formulated by all provincial competent authorities.
A safety information code (basic information) will be automatically generated for chemical products, imported chemicals and partial operating chemicals. You can edit additional customized information (expanded information, such as packing specifications, etc.) based on your needs and a new safety information code will be generated accordingly.
7. How to define the plant layout and fill in its coordinates?
When several plants are not adjacent to each other or located in different regions with relatively independent managements, multiple plant layouts can be drawn based on the actual situation. Plant layouts and its coordinates will be directly added into the system.
8. Do I need to submit certifying documents in paper?
No. Enterprises only need to submit the certifying documents online since 2020.
9. Do I need to log in the new system if my certificate obtained under the previous system is still valid? Why the QR code cannot be downloaded after I have log in the new system?
Compared with the previous system, the new system requires additional information. As a result, manufacturers and importers are required to supplement relevant information as soon as possible. Once the information is complete, the QR code will be generated and be available to download.
10. If the CAS number of a chemical is not listed in the Catalog of Hazardous Chemicals (2015), do I need to complete hazardous chemicals registration?
Firstly, according to the Measures for the Administration of Registration of Hazardous Chemicals, chemicals that are not listed in the Catalog shall be identified based on the known information and products. If they conform to the determinative principle of hazardous chemicals, registration of hazardous chemicals is required yet relevant safe-use administrative permit is not needed.
Secondly, the Catalog is made subject to chemical category name in Chinese on the grounds that CAS number simply functions as an auxiliary mark. For example, when the name of a chemical is listed in the Catalog while its CAS number is different from that in the Catalog, the chemical is still considered a hazardous chemical listed in the Catalog.
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