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Comparison of 'China REACH' 2003 and 2010

'China REACH' is commonly used as a shorthand way to refer to China's regulation of chemical substances. First implemented on October 15, 2003, it was substantially revised on October 15, 2010.

No change from China REACH 2003 to China REACH 2010:

A notification must be submitted and a registration certificate received prior to the manufacture/import of a new chemical substance in China.

Only "new" chemical substances are covered. Chemicals listed in the Inventory of Existing Chemical Substances in China (IECSC) are not included. Currently new chemical substances are followed for a five-year period before being listed in the IECSC. 

Eco-toxicological testing in China with Chinese organisms must be submitted with the Notification Form.

New provisions in China REACH 2010:

Only domestic Chinese companies may submit a Notification.

Data requirements increase for notifications of quantities over 1 tonne per year: more detailed test data for physico-chemical properties, toxicity and eco-toxicity; more detailed environmental risk assessment report; new requirements for classification & labeling information and a safety data sheet.

Increasing data requirements for quantity bands: 1-10 tonnes, 10-100 tonnes, 100-1000 tonnes, over 1000 tonnes

Chemical substances will receive one of three classifications: "general", "hazardous", or "of environmental concern". Appropriate risk control measures will be required for substances of environmental concern.

Increased risk management obligations for registrants, the supply chain and end-users, including hazard and exposure measures for labeling, packaging, transportation and disposal.

This summary of changes to China PEANCS is designed to provide you with an accurate, easy-to-understand overview of the topic and does not constitute legal advice. The actual standard in the original language should be reviewed and used for all business, legal, and product compliance purposes.

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