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Which substances are affected?

All substances which are not listed in the "Inventory of Existing Chemical Substances manufactured or imported in China (IECSC)" independent of the yearly tonnage are new substances and need to be notified. At the moment there are over 45000 substances listed in IECSC, over 3000 of these cannot be searched from outside because of confidentiality agreements.

The following substances are exception from this regulation:

- Chemicals which are subject of other Chinese regulations or laws (e.g. pharmaceuticals, pesticides, , radioactive material, veterinary medical substances, cosmetics, food and food additives, fireworks, tobacco and tobacco products, military products);

- Natural substances:
- Which are unprocessed or only through manual labor, mechanically, through gravitation, water solubility, floatation or dehydration;
- Which are harvested from the atmosphere;
- Which are natural polymers; which are not altered by physical or chemical processes;

- Non commercial products or products that are produced by accident, e.g. impurities, side products, waste and products which are produced during storage of the main product;

- Special categories, e.g. glas, molten masses, ceramics, steel products, cement, alloys, non-isolated intermediates.

A key difference to EU REACH is that polymers are not exempt of the notification. It is necessary to file a notification of the polymer even if all monomers are listed in the IECSC as long as the polymer itself is not listed. Also, raw materials and intermediates of pharmaceuticals, pesticides, veterinary medication etc. are subject to notification as long as they are not listed in the IECSC.


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