*Taiwan Taiwan’s Ministry of Labor answers frequently asked questions about Priority Controlled Chemicals

Taiwan’s Ministry of Labor answers frequently asked questions about Priority Controlled Chemicals

On April 1, 2022, the Taiwan Ministry of Labor released a document on frequently asked questions and answers regarding “Priority Controlled Chemicals” notifications. For example, to the question, “A Priority Controlled Chemical is also a toxic chemical, and I have already declared it as a toxic chemical, but do I need to report it as a Priority Controlled Chemical?” the answer is given “Since the purpose and rules of control by each central authority are different, for chemicals handled by business operators, it is necessary to report and notify Priority Controlled Chemicals to the Environmental Protection Administration in accordance with the regulations, even if the report as a toxic chemical has been completed.”

Question & Answer Example

The following are some of the questions and answers provided in the Q&A document.

Question

Answer

As an importer, we perform paper transactions and there is no actual storage location. Do we need to file a report or notification? According to Article 3 of the “Designation of Priority Controlled Chemicals and Handling Control Law” (hereinafter referred to as the “Law”) the handler includes the manufacturer, importer, supplier, and employer. Therefore, if the importer falls under the category of importer or supplier specified in the Law, it will be subject to the Law.
The list of target chemicals was announced on February 14, 2022. In accordance with the provisions of Article 7 of the “Law,” will the list be notified within 6 months or 18 months from the effective date of the public notice? When a new chemical product is announced, the provisions of Article 7 of the “Law” shall apply. The Priority Controlled Chemicals List, which was announced on February 14, 2022, has only been reclassified, and no new chemical products have been added. Therefore, for notified chemical products, it is necessary to submit a notification according to the date related to the periodic report.
How does the list of Priority Controlled Chemicals that applies from April 1, 2022 differ from the previous list? Compared to the previous list, 25 chemicals have been removed from the new list. When the relevant reference materials were updated, it became clear that the chemicals did not fall under the provisions of Priority Controlled Chemicals and they were therefore deleted.

 

The original text of the above document can be viewed at the following URL (in Traditional Chinese):
https://prochem.osha.gov.tw/content/info/DownloadList.aspx?Classify=2

Author / Responsibility

AOKI Kenji

Senior Consultant, EnviX Ltd.
General Director, E&H Consulting Co., Ltd.

Business Performance

Expertise in EHS (environment, health and safety) consulting in ASEAN region.
- Environmental regulations updating
- Chemical regulations consulting

Background

MSc in Earth Science, The University of Tokyo

AOKI Kenji