Taiwan has put up on public domain its chemical inventory list. All those substances not listed on the chemical inventory data would be termed as a new chemical as per Taiwanese regulation and invites a registration to be placed in Taiwanese market.
For those substances already listed in the Taiwan Chemical Inventory List, the registration window for phase 1 registration was open from 1st September 2015 until 31st March 2016. Eligibility for registration is for all substances imported or manufactured above 100 kg per year.
Taiwan also has brought out a phase 1 designated substance list, and for substances falling under this category, a window for its registration will be made available at the earliest by the authorities. Likewise, there will also be a list of phase 2 designated substances which will be published soon by the authorities.
For the new chemical substances not listed in the Taiwan Chemical Inventory List, the threshold for registration is 100 kg per substance imported or manufactured by Taiwanese entity.
There are steps to check for the exemption of substances if they fall under the categories of scientific or for research-oriented developments. Once the type of registration is determined, one has to carry out the registration depending upon the category viz.
- a) Simple Quantity Registration
- b) Simplified Registration and
- c) Standard Registration
which again is based on the tonnage band which ranges from 100 kg per year to 1000 tonnes per year and more.
For those substance belonging to Carcinogenic Mutagenic & Reproductive (CMR) type, they have to undergo a standard registration.
However, data requirement would depend on the tonnage volume per year.
In Taiwan, there are no obligations for annual reporting of the chemical substance. However, the major difference compared to the EU and Korean REACH regulation is that in Taiwan, registration will be carried out only under the name of the Taiwanese Importer or Taiwanese Manufacturer.
For the non-Taiwanese entity, registration formalities can be carried out by appointing an Only Representative but the POA for such registration will be obtained from the Importer and or manufacturers in Taiwan. This scenario of registration by a non-Taiwanese manufacturer arises only when the importer of their products into Taiwan does not reveal to the supplier of the raw material the registration status.
In this regards, it is advised that a certificate of compliance from the importer is collected by all non-Taiwanese manufacturer to ensure compliance and avoid business loss. Penalty, as decided by the Taiwanese Authority has to be borne by the Taiwanese entity for non-compliance to regulation.
Trust House Solutions in cooperation with Taiwanese Regulation compliance service provider, support the non-Taiwanese manufacturers having business in Taiwan. Our expertise in the said regulation facilitates them to make them abreast with the requirements and guide them to safeguard business growth in Taiwan ensuring regulation becomes no embargo.
We always say
“The first business comes by luck but continual orders happen only through endurance and by complying with statutory requirements”