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The 2021 Project of Implementation Management and Import/Export Permit Reviewing for Toxic Chemical Substances

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The goal of this project is to keep up with international chemical substance regulations and to keep track of domestic handling data of Toxic Chemical Substance (TCS). To make improvement proposal for TCS screening criteria, handling management items and the classification of class 4 TCSs, regulatory updates from The United States, European Union and four International Conventions (eg. Stockholm Convention) are gathered this year. Additionally, for clarifying domestic management mechanism of articles containing TCS, analysis of TCS permits and reported data, as well as questionnaires are used to provide in-depth information that such articles are mainly in forms of semi-finished products requiring further process or products that will not enter common consumer channels directly. On the aspect of TCS border management, this project has assisted handlers with applying for TCS import permits and received 676 applications (with a total of 587 permits issued). Majority of commodities applied (52.64%) has c.c.c. code 3808.92.20.90-4 (other fungicides products), followed by c.c.c. code 3808.91.90.00-9 (other insecticides products). Besides, in accordance with “Restrictions on the Importing of Mercury-Added Products ", the project has assisted with 5 preliminary reviews of import application for mercury-added products. To improve the accuracy of reported TCS release data, the reported data in 2020 of 30 TCSs designated in Toxic Substance Release Calculation Guidance has been reviewed and the finalized ducument is released to the public. Reported data from 708 handlers has been reviewed this year and a list of 350 companies with suspecious reported data is provided to local Environmental Protection Bureaus for conducting on-site inspections or guidance process. In addition, for the handlers reporting largest handling quantities in 2020, handling wide variety of TCSs in factories and having questions about TCS release data reporting, 10 on-site consulting sessions have been conducted to offer consultation for the factories on the incorrect or suspecious reported data and to provide concrete suggestions according to their actual chemical process, making reported data more in line with the real situation. Meanwhile, in response to newly designated concerned chemical substances (CCS), this project has adjusted multiple functions of Toxic Chemical Substances Registration and Declaration System (TCSRDS) in accordance with regulatory timelines, including diversion interface for TCS and CCS, online exemption application for adding sulfur dioxde to nitrous dioxide (laughing gas), online applicaion for approval and reporting handling record of ammonium nitrate and hydrofluoric acid. Furthermore, for making the administrative function more user friendly, the project has developed comparison table for permit/approval change, checked and combined different administrative functions and introduced 3 visualized reports. Moreover, for solving system related problems and regulatory questions for handlers efficiently, the project consistently provides a service number with 6 lines as the frontline user consultation channel. The average number of requests is 894per month. With three orientations for handlers, one orientation for local Environment Protection Bureaus and one review meeting, this project has assisted handlers and administrative units in familiarizing with TCSRDS and related regulations.
Keyword
Toxic Chemical Substances, Release Quantity of Toxic Chemical Substances, Import and Export Regulation Code 801-5 and 837-6
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