REGULATION & COMPLIANCE
EU REACH
ICMSR
Pre-registration ( free ) Notification ( for apply )
Substance details , tonnage and company
Tonnage and data updates
Registration of a substances
Additionally : Uses , downstream users , spectra , hazard class , SDS
Annual reports or all substances
Registration of schedule II substances only
Tonnage-specific deadlines Common deadline ( all tonnages )
Substances : SVHC , CoRAP , restriction , authorisation
Figure 2 - Comparison of EU REACH & ICMSR
concern remain unregulated in India , highlighting the critical need for a more comprehensive approach . This is now being undertaken .
A comprehensive approach
The fifth draft of the Indian Chemical ( Management & Safety ) Rules ( ICMSR ) was released on 24 August 2020 . The ICMSR will regulate substances , substances in mixtures , and substances in articles and intermediates manufactured , imported or placed in Indian territory .
The legal basis for the ICMSR is found in Sections 3 , 6 and 25 of the Environment Protection Act ( 1986 ). Its promulgation will result in the suspension of the two existing rules mentioned above . The proposal introduces a phased approach to chemical regulation .
Phase I includes notification and the creation of an Indian national chemicals inventory , a critical first step in identifying and cataloguing chemicals in the Indian market . As a first step the platform for the inventory , ChemIndia , was launched in October 2023 .
Phase II will move towards the registration , evaluation and categorisation of chemicals , focusing on those identified as priorities due to their hazardous nature . Figure 1 illustrates the registration and notification deadlines to be followed in Phase II of the implementation of the ICMSR .
Substances : Priority , schedule II , hazardous , restriction & authorisation
The ICMSR will cover all chemicals present in the Indian market and will adopt a precautionary approach that shifts the burden of proof to manufacturers . This approach requires chemicals to be proven safe for human health and the environment before they can be manufactured , imported or used , thereby ensuring a higher level of protection . This comprehensive approach covers acute and chronic effects and addresses concerns about carcinogenicity , mutagenicity , reproductive toxicity , and persistence and bioaccumulation in the environment .
Anticipated effects
By promoting a safer chemicals industry , the ICMSR is expected to drive innovation towards greener and more sustainable chemical processes and products . This push towards innovation can open up new markets for Indian companies and enable them charge premium prices for high quality , environmentally friendly products . In addition , the regulation can stimulate job creation in areas such as chemical safety assessment , environmental monitoring and compliance management , further strengthening the economy .
The implementation of ICMSR is expected to significantly reduce the incidence of chemical-related health problems and environmental damage . By regulating substances of concern , including those that are persistent , bio-accumulative and toxic to aquatic life , the rules aim to mitigate longterm impacts on biodiversity and ecosystem services . Furthermore , the focus on accident prevention and management of hazardous chemicals is likely to lead to a reduction in industrial accidents , protecting workers and surrounding communities .
As the global chemical industry evolves , regulations will inevitably become more stringent , driven by advances in scientific understanding and societal expectations . The ICMSR positions India not only to meet current international standards but also to adapt to future developments . It establishes a dynamic framework that can accommodate new scientific knowledge and technological advances , ensuring that India remains at the forefront of chemical safety and sustainability . Figure 2 compares key aspects of the ICMSR with EU REACH .
Conclusion
ICMSR is more than a regulatory requirement ; it is a strategic imperative for India . By addressing the current gaps in chemical management , the ICMSR lays the foundation for a safer , more sustainable and economically vibrant chemical sector .
It reflects a balance between economic development , public health protection , and environmental sustainability and positions India as a responsible and forward-looking participant in the global chemicals market . The successful implementation of the ICMSR will mark a significant milestone in India ’ s journey towards sustainable development and international compliance , ensuring a safer future for its citizens and the natural environment . ●
Shisher Kumra
FOUNDER & CHIEF EXECUTIVE
GPC GROUP k + 46 46 211 46 15 J compliance @ gpcregulatory . com j www . gpcregulatory . com
48 SPECIALITY CHEMICALS MAGAZINE ESTABLISHED 1981