USCIB Opposes Stringent Chemicals Regulations in China

Test_tubesOn July 30, USCIB submitted comments to China’s Ministry of Environmental Protection expressing concern with draft language in China’s recently revised guidance on new chemical substances. New language suggests that any new chemical substance in an article that could potentially result in exposure to the environment or humans will be subject to full chemical notification obligations.

USCIB noted that this new requirement would be unnecessarily burdensome, imposing exorbitant costs on importers of articles. Importers would face challenges in obtaining information about the presence of chemicals in articles in order to assess potential compliance. This requirement would be imposed even if there is no corresponding benefit to the protection of human health or the environment.

“In others countries, chemical registration or new chemical notification requirements are much more limited with respect to chemicals in articles,” said Helen Medina, USCIB’s vice president for product policy and innovation. “It is not technically or economically feasible to test every article for every chemical that might be contained in each article.”

USCIB members support efforts to protect human health and the environment, and comply with a variety of national regulations including those specific to chemicals.  For this reason, USCIB is actively engaged in the Strategic Approach to International Chemicals Management (SAICM), chemicals and green economy discussions at the United Nations Environment Program (UNEP), and chemicals deliberations at the Organization for Economic Cooperation and Development (OECD) and at the Asia-Pacific Economic Cooperation (APEC) chemical dialogue.

Staff Contact:   Michael Michener

VP, Product Policy and Innovation & Acting Program/Policy Co-Lead
Tel: 202.617.3159

Michael Michener is USCIB’s vice president of product policy and innovation, joining USCIB in early 2017. Michener is a former administrator of the U.S. Foreign Agricultural Service who has also served as a U.S. trade diplomat and association executive. Michener most recently served in Brussels as director of multilateral relations for CropLife International, representing the association before a range of international organizations – including the UN Food and Agricultural Organization, the UN Environment Program and the UN Framework Convention on Climate Change – on issues related to crop protection products and agriculture biotechnology.
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