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Lynn L. Bergeson is managing director of Bergeson & Campbell, P.C., a Washington, D.C., law firm focusing on conventional and engineered nanoscale chemical, pesticide, and other specialty chemical product approval and regulation, environmental health and safety law, chemical product litigation, and associated business issues, and President of The Acta Group L.L.C. and The Acta Group EU Ltd. with offices in Washington, D.C., and Manchester, U.K.

Taiwan Expected to Publish Draft National Inventory of Existing Chemicals at End of 2011

July 12, 2011
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Once Taiwan establishes a final inventory, it will focus on the next phases of its chemicals management strategy involving risk-based screening and management of chemicals and disseminating information on chemicals to the public.

Taiwan is likely to publish a draft national inventory of existing chemical substances by the end of 2011. During an interagency meeting held the week of June 20, 2011, participants chose to delay publication of the draft inventory to align it with legislation for new chemicals notification. Taiwan will introduce new chemicals notification by amending two laws – the Labor Safety and Health Act (LSHA), managed by the Council of Labor Affairs, and the Toxic Chemical Substance Control Act (TCSCA), which is under the responsibility of the Environmental Protection Administration. The Executive Yuan passed a review of proposed amendments to the LSHA in May 2011, and it is now awaiting formal approval. Taiwan sent a notification of the proposed amendments to the World Trade Organization's Technical Barriers to Trade Committee in June. The Legislative Yuan, which reconvenes in September, will now need to review the proposed amendments.

Nominations for existing chemical substances were due Dec. 31, 2010. According to Taiwan's Council of Labor Affairs, it confirmed approximately 64,200 substances as unique entries. Of these, about 2,100 substances were reported at over 1,000 metric tons annually and 24,000 substances over one metric tonne annually. Most of the nominators were from Japan, Korea, the United States, Canada, Australia, and the European Union. Half of the nominators were in the following industry sectors: chemical materials industry; international trade industry (chemical suppliers); and other chemical industry.

Taiwan reportedly intends to allow a "supplementary notification" of chemicals to the existing chemicals inventory, probably later this year. Once Taiwan establishes a final inventory, it will focus on the next phases of its chemicals management strategy involving risk-based screening and management of chemicals and disseminating information on chemicals to the public. This could include restrictions and permitting for chemicals of concern.
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