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“REACH” REACHES THE FAR EAST

Wednesday, May 28, 2014  
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“REACH” REACHES THE FAR EAST

It seems a shame that every country, not matter how small, seems to want to reinvent the wheel with a different chemical control program. The latest two countries to burden the chemical industry are Taiwan (TCSCA) and Korea (K-REACH). Taiwan’s program goes into effect in December of this year; Korea’s at the beginning of 2015. Here we can only summarize the key points; if your company exports to Taiwan or Korea you need to know much more.

Both countries distinguish between existing chemicals and new substances just like European REACH, and both programs require all manufacturers or importers of a given chemical to make a joint submission. Korea requires the entities to be Korean, as in Europe, but Taiwan allows foreign registration.

New chemicals must be registered in advance of import or manufacture. Existing chemicals must be registered and “phased in” based on volume and level of risk. The test requirements are as comprehensive as for Europe. The higher the volume, the more data required and the earlier you must register. Korea includes polymers; like Europe Taiwan largely exempts them. Both programs require annual reporting. A company must evaluate the potential cost of this program when deciding whether to continue exporting to Taiwan or Korea.

Initial nomination of chemicals to the Taiwan Inventory was done in 2012, but there will be a Supplementary Nomination and Correction period in 2014.

If you export to Taiwan you should:

         Draw up list of substances and their volumes exported to Taiwan

         Check the Taiwan Chemical Substance Inventory - online

         Take advantage of the planned secondary nomination period summer 2014

         Monitor final stages of passage of TCSCA – especially with regard to existing chemical registration

         Identify if any substances of interest classified as “toxic chemical substances” regardless of which of the 4 classes

         Full GHS implementation, classification and labeling of hazardous chemicals: January 1st , 2016

 
Article authored by Nelson Lawson on behalf of the PCA Product, Regulatory & Stewardship Committee