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Toxic Chemical Import and Export
Import and Export control of Toxic Chemicals in China started from year 1994, which is based on 'London Guidelines for the Exchange of Information on Chemicals in International Trade' and Prior Informed Consent PIC.
China Regulation 'Regulation on Environmental Management for First Import of Chemicals and for First Import and Export of Toxic Chemicals' (China EPA Order  No. 140) rules that import and export of toxic chemicals as listed in 'Catalogue of China Strictly Controlled Toxic Chemicals for Import and Export' (the Catalogue) shall obtain 'Environmental Management Registration Certificate for Toxic Chemical Import/Export' (Certificate) and get 'Environmental Management Release Permit for Toxic Chemical Import/Export' (Release Permit).
The Catalogue is revised from time to time. The latest one is version 2014 (issued in December 2013 as MEP Order  No. 85), including 162 chemicals e.g. Inorganic or organic compound of mercury, PCT, PCB, PBB, nonyl phenol, nonylphenol ethoxylate, etc..
China EPA (now called 'Ministry of Environmental Protection of China', China MEP) sets up Evaluation Committee to be responsible for the evaluation of application materials.
Companies outside China that exports toxic chemicals to China shall apply for the Certificate. After approval, the Certificate will be issued to the exporter. Then, the corresponding China importer shall apply for the Release Permit. This Release Permit will enable the importer to make customs declaration at China customs.
The Certificate is valid for 2 years. The Release Permit is valid for 6 months. Each shipment to China shall need one Release Permit.
In 2009, China EPA issued 'Notice on Strengthening Environmental Management Registration of Toxic Chemicals Import and Exports', ruling that China users and manufacturers of toxic chemicals shall compile 'Environmental Protection Report' for the applied toxic chemical and get approved, only then the Certificate and/or Release Permit can be applied. This is a challenge for the application, and it is a key new point for toxic chemical management in China.
Another technical requirement for the application is to provide Safety Date Sheet (SDS) for the application. The SDS shall be precise, and list management requirements of the toxic chemical in the country of the exporter.
It also rules that toxic chemical companies in the supply chain of Release Permit and of the Certificate shall make annual reporting before each January end.
The other parts of the application is a kind of formality work, not so difficult.
It takes normally 3 months to obtain the Certificate. The Release Permit normally takes 2 months. For imported toxic chemicals, the Release Permit can only be applied after the Certificate is obtained --- it means around 6 months are needed to be able to import a toxic chemical into China, including the time for Environmental Protection Report, for the Certificate application and for the Release Permit application.
And, 10,000 USD or equivalent Chinese Yuan shall be paid to MEP for the application of the Certificate.
Currently, the Regulation is being revised. Afterwards it is expected the 10,000 USD fee will be exempted, and the number of toxic chemicals in the Catalogue will be reduced.
Should any assistance is needed for the application, Randis can be contacted.
Appendix: Certificate example.
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