Shanghai has numerous chemical-related enterprises, including manufacturers and importers. Chemical enterprises and downstream users in the city are the first to be inspected in the annual environmental enforcement inspections. To avoid being punished for violating the Measures for the Environmental Management Registration of New Chemical Substances (MEE Order 12), enterprises need to formulate strategies to properly cope with the law enforcement inspections.
Based on our previous experience, CIRS Group recommends that enterprises should focus on the following items prior to inspections:
- Check all chemical substances manufactured, imported, processed, and used;
- Randomly inspect chemical substances and determine whether they are subject to relevant notifications or whether they are subject to new use management;
- Check certificates and documents obtained such as business licenses, registration certificates, and record receipts;
- Check standing books or relevant records of registered or recorded substances;
- Check records of pollution control facilities concerning registered substances;
- Randomly inspect registered or recorded substances to confirm their authenticity;
- Check the implementation of specified items such as the registration volume and risk management measures; and,
- Verify the information transmission, such as conveying messages and evidence in both electronic and written forms.
Of all the items above, the second one is the basis for self-examination and compliance. Only when conditions in the second item are met can the following compliance be conducted. Therefore, it is essential for enterprises quickly and accurately identify their substances and check whether new chemical substances are included in their products. Considering the variety of products and the irregular update of the IECSC, it is challenging for enterprises to determine what kind of obligations they should fulfill.
(The Inventory of Existing Chemical Substance in China – IECSC (2013 and updates))
CIRS Group has prepared a free inventory search system- APCISS, through which related enterprises may quickly check whether a substance is listed in IECSC by CAS number.
CIRS Group will continue to share relevant information on how to properly comply with law enforcement inspections on new chemicals in Shanghai.
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