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Surveying and inspecting project for post-market chemicals, 2020

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The principal work of this project could be divided by three parts, including surveying and inspecting for post-market chemicals, to establish a verification mechanism for toxic and concerning chemical substances online trading, and to promote cooperation in border-management of chemical substances. First, total 326 manufacturers and importers had been surveyed and inspected for toxic chemical substances (TCS), importing asbestos-containing goods, Import Regulation Code 801-5 or 837-6, new and existing chemical substances, and green chemical production. A variety of activities were conducted during the inspection and counsel, including but not limited to, regulatory compliance, substance appearances, substance applications, final products, and residual concentration of toxic chemical substances. Meanwhile, the distribution of downstream industries was traced to comprehend the chemical supply-chain. There were 242 industries related to toxic chemical substances under inspection and counsel. 86 types of toxic chemical substances were used as raw materials, additives or solvents, and involves 120 types of manufacturing processes. The following manufacturing processes are the most common ones; Manufacturing processes for other chemicals, acrylic resins, other synthetic resins, or plastics. The semi-manufactures are acrylic resin, phenol resin, and synthetic rubber. The concentrations of the mentioned semi-manufactures were mostly lower than control standard, where the residual concentration of some industrial catalyst reached the control standard. Regarding the counsel of green chemistry manufacturing, 10 industries that were related to nonylphenol ethoxylates use in industrial detergents, lead chromate and lead chromate molybdate sulphate red use in paints were selected to counsel the manufacturing process adjustment and substitute. The industries have received the relevant information and been willing to test the substitute batch by batch. Moreover, these industries suggested that the target toxic chemical substances should be banned or restricted to regulate consumption in the industry. Without the low-cost target toxic chemical substances to choose from, this will help downstream industries to increase the acceptance of using eco-friendly alternatives, and reduce the consumption of toxic chemical substances. For the network checking, daily keyword searching on 9 domestic e-commerce platforms was implemented. The sellers were advised to discontinue selling doubtful chemicals or goods on the website. This project complies to the Toxic and Concerned Chemical Substances Control Act which adds new prohibition of toxic and concerned chemical substances sales in e-commerce. Domestic e-commerce platform operators were proactively invited to take part in seminars and provided with controlled chemical substances list, including Chinese name, English name, CAS number and common names for regularly self-checking before selling online. Meanwhile, they were suggested to establish a self-management system for inspection such as announcement, alert window to remind seller, independent chemical category, and avoidance of confusing words. These suggestions may help to avoid penalty due to unfamiliar of law. There were 11,081 high-risk lists until 25th December 2020, while 5 of them were classified as doubtful goods which were no longer be sold after informing platforms. Moreover, nitrous oxide was listed as concerned chemical substance on November 30th 2020, and it was banned from selling on the online platforms at the same time. Therefore, the project focused on inspecting nitrous oxide selling on the online platforms, and 31 online platforms were suggested to discontinue selling or adjust information of 146 goods before the announcement. 2 online platforms continued the selling of nitrous oxide after the announcement, which were reported to Toxic and Chemical Substance Bureau, and penalties were imposed by the environmental agency. Regarding border management, the importers of the toxic chemical substances have to obtain the permit from the municipal or prefecture (city) competent authority, and comply with regulations from the Custom Administration, Ministry of Finance. To understand the process of bonded warehouse and logistics center, 183 bonded warehouses and logistics centers were checked. 110 bonded warehouses or logistics centers did not store chemicals, 40 of them stored chemicals, 19 of them with toxic chemical substances permit (approval) documents have stored chemicals or toxic chemical substances. Moreover, 3 bonded warehouses and logistics centers with toxic chemical substances permit (approval) documents were visited to have a good knowledge of operation process of customs clearance, including customs declaration, tax payment, delivery and warehouse transfer. A search function of safety data sheet was established for importers of toxic chemical substances. 4 training sessions of customs operation and conferences of border management cooperation were held to assist customs to decide whether the imported goods are toxic chemical substances, and enhance border management.
Keyword
Toxic and Concerned Chemical Substances, Post-Market, Investigate Manufacturing Process, Counsel of Manufacturing Process, E-commerce Inspections, Border Management
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