Country Specific Registration
Trust House Solutions would give up claims to have visited all the countries to which we render regulatory services, however, de facto, we have a decent understanding of specific regulatory requirements of each country in which our clients are interested and currently export their products.
Preparing a list of chemical inventory is the first step in the process of implementing chemical management plan in order to understand what kind of chemicals are being used in that country (manufacturers of that country & importers/distributors). Many countries already have in place a sound chemical management plan (chemical control plan) where the EU has taken the lead to implement REACH in 2007 (Regulation (EC) No.1907/2006).
This chemical inventory exists in various countries like USA, EU, China, Taiwan, Philippines, Taiwan, Japan, Korea, New Zealand, Australia, Canada, etc. India shall soon be coming up with its own chemical inventory list and chemical legislation as per final draft on national chemical policy’14 which may contain data on production, consumption, imports, exports, toxicological properties and classification criteria akin to Globally Harmonised System of Classification and Labelling (GHS).
It will be mandatory for the chemical substances that are exchanged across the countries to be listed in these global chemical inventory list for the finished products may be sold across the globe.
Please refer our country wise listing page for more information specific to the regulatory requirement.
As knowledge about chemicals is on a rampant high, more understanding about its end-use and impact on human health and the environment is brought out by regulatory authorities. This also keeps a check on the volume of substances that enters and leaves a country in the form of import & export.
In line with European REACH, there are REACH and REACH-like regulation in countries like China, Taiwan, Korea, Turkey (will soon come into force) under their respective chemical management plan where products are required to be registered depending upon its use and volumes exported in that country. There are certain exemptions as well.
None of these country specific regulations are to be considered as trade embargo, for it is helping to regulate the flow of chemicals that are safe for use and to protect the environment. Certain chemicals are totally banned for use while there is relaxation for many and; for few, alternative chemical substances are identified to replace more toxic components.
As the world gets educated for better, substances of very high concern (SVHC) list will keep on increasing and with globalization & innovation, safer chemicals will be made available.
Exemption from Registration
Under chemical legislation, certain category of substances are either fully or partially exempted from registration (which means companies are allowed to document evidence towards such exemptions or do the needful as demanded under relevant legislation requirement to export those substances without incurring full cost of registration).
This is mainly because there already exists other similar or stringent legislation for the use of such substances. This includes the use of the substance as a:
- Food additive in foodstuffs
- Flavouring in foodstuffs
- Additive in feeding stuffs
- Animal nutrients
- Medicinal products
Exemption may also apply to substances which are originating from nature and being made available to the market as it is without any chemical treatment (e.g. Castor oil), they are considered to cause minimum risk to human health and the environment.
We always say
“Change is inevitable, and we need to keep pace with it to safeguard our business and future”.