• New chemical substances , which have to be registered before they are manufactured in or imported into China under Ministry of the Environment & Ecology ( MEE ) Order No . 12 , also known as ‘ China REACH ’.

• Existing chemicals , which still require further management after being registered if they are hazardous

• The Globally Harmonised System ( GHS ), which is managed under

‘ China GHS ’ - companies need to ensure that their products are classified according to this rather than any other classification systems Different chemical inventories exist in China ( Figure 2 ), within the scope of the Inventory of Existing Chemical Substances in China ( IECSC ). If a chemical is not included in any of these , it is classified as a new substance . Companies wishing to place new substances on the market should consider if they are likely to be classified as hazardous under the GHS classifications , then if it is included in the 2015 Catalogue of Hazardous Chemicals and finally if further management will be needed because it is toxic , explosive or a precursor .

China REACH

The first version of what is now China REACH dates back to 2003 when SEPA Order No . 17 was implemented . Since then , there has been a long process of revision and change until April 2020 , when MEE Order No . 12 was published . It has been implemented since 1 January 2021 . Substances that are not listed in the IECSC and those that are but which have a new use management are both subject to registration under China REACH . You can check if a substance is listed on

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Figure 1 – Chemical management framework in China

42 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981