Submitted comments to MEE on Guidance on the Environmental Management Registration of New Chemical Substances

2020-09-06 | Beijing, Shanghai

On 6th September, the European Chamber's Environment and Petrochemicals, Chemicals and Refining Working Groups submitted input to the Ministry of Ecology and Environment (MEE) on the draft Guidance on the Environmental Management Registration of New Chemical Substances. 

Comments were submitted jointly with the China International Business Dialogue on Environmental Governance and the US-China Business Council.

Members noted some positive aspects of the draft guidance, including reduced data requirements on specific products and shortened review times. However, there are number of areas that will increase burdens for registering new products and increase costs and lead-time for investors. Investment in new innovative products is strengthened with strong intellectual property guarantees, and the approval of confidential business information (CBI) requires new prerequisites that will make it more difficult for companies with innovative products to bring them to market. Moreover, a lack of transition period may lead to registrations prepared over the past 2-3 years to have to restart the process, further delaying products from entering the market. Members hope that the MEE will consider reducing data requirements that will increase costs and time to market, and make it more challenging for companies to introduce new innovative products, particularly those companies with essential CBI. Members also proposed small-volume exemptions for substances <100 kg/year for R&D purposes.