Pay attention to these compliance of the "New Chemical Substances Environmental Management register" in order to avoid "those" violations!-Zhongbang Registration Compliance

Pay attention to these compliance of the "New Chemical Substances Environmental Management register" in order to avoid "those" violations!

Apr. 16th, 2024

Since the New Environmental Management Registration Measures for Chemical Substances (hereinafter referred to as the "Measures") came into effect on January 1, 2021, it has been comprehensively promoted by the Ministry of Ecology and Environment and has made good progress.

A few days ago, the Publicity Department of the CPC Central Committee held “ China's decade ” At the main press conference of the series, Huang Runqiu, Minister of Ecology and Environment, also introduced the ecological and environmental protection work, and mentioned “ Five overall planning” . Among them, traditional pollutants and new pollutants should be coordinated, and it is pointed out that a new risk prevention and control system for chemical substances should be established in particular. What the new chemical substances environmental management register is doing is risk control.

At the national governance level, the "Action Plan for the Treatment of New Pollutants" issued by The General Office of the State Council on May 4 this year raises the importance of the treatment of new pollutants to an unprecedented height, which also emphasizes the importance of the environmental management registration of new chemical substances. To carry out the environmental management registration of new chemical substances is one of the most direct measures to implement the Action Plan for the Treatment of New Pollutants.

Based on the rich registration experience of Zhongbang Consulting, combined with the practical operation experience of the team and the exchange with the official, the difficulties and pain points commonly encountered by enterprises in the actual registration work, including polymer filing, cumulative environmental risks in simple registration, information protection, etc. I hope it can help enterprises carry out compliance work smoothly.

According to the requirements of the supervision and follow-up management of new chemical substances in the later stage, the Law Enforcement Bureau of the Ministry of Ecology and Environment issued the Guide for the On-site Inspection Work of the Environmental Management of New Chemical Substances to provide guidance for the local ecological environment authorities to carry out the corresponding on-site inspection work.

At the same time, a new local regulatory information system for chemical substances has been developed to serve the step-by-step notification system and realize information sharing and information transmission.

Such a combination of measures provides an important tool for the development of subsequent regulatory work.

On-site inspection is the landing work of environmental supervision, and the Guide for On-site Inspection Work of New Chemical Substances Environmental Management guides local ecological environment departments to carry out corresponding on-site inspection work.

Taking Shanghai as an example, on-site inspection is mainly divided into the following five steps:

Enterprises should pay special attention to the relevant substances according to the requirements of the new chemical substance environmental management registration, and ensure the authenticity of the registration items, the implementation of the registration certificate. In particular, the production or import of new chemical substances without obtaining a registration certificate should be strictly prohibited.

This is because of the 47 punishment decisions issued to 15 provinces and cities since 2021, the main illegal acts should be reported, and the three cases published on the official website of the Ministry of Ecology and Environment are similar. Please take this as a warning and pay attention to compliance.

For registered substances, registration does not mean the end, and different types of registration have different post-registration obligations. Information transfer, data preservation and activity recording of new substances are also a top priority.