Overseas Services

Domestic companies must respond to registration, notification, and classification/labeling regulations according to each country's chemical management system for smooth export of chemicals or products. In this regard, the services provided to respond to overseas chemical substance regulations are as follows.

Toxic Substances Control Act(TSCA)

Substances not listed on the TSCA Inventory are considered as new chemicals, and in the case of manufacturing/importing new chemicals, a Pre-manufacture Notice (PMN) is issued to the Environmental Protection Agency (EPA). There is an obligation to report Notice Of Commencement (NOC) at the time of commencement of manufacturing/importing.

Premanufacture Notices (PMNs) & Signiﬁcant New Use Notices (SNUNs):

If your chemical substance is subject to Signiﬁcant New Use Rules (SNURs) and your intended manufacture, processing, or use of the substance is a signiﬁcant new use, you would be required to submit an SNUN 90 days prior to the manufacture of that substance.

Our Services
- Application for pre-manufacture exemptions
- Preparation of PMN dossiers
- Reporting beginning of manufacture/import with NOC
- Notice of manufacture/import activities(NOA Form B)
- Review whether chemical is subject to SNUR- Setting safety test strategies, arranging/monitoring tests

REACH(Registration, Evaluation Authorization and Restriction of Chemicals)

Within the EU, under REACH regulations, all chemical substances which are imported at 1 ton or more annually are obligated to undergo registration(in case of mixtures, each individual constituent substance must be registered).

Businesses outside the EU may register by appointing an OR(Only Representative).

Our Services
- Support for OR appointment process
- Service on registration/notiﬁcation, permits, performing duties on restrictions
- Providing latest news regarding REACH
- Setting safety test strategies, arranging/monitoring tests

India REACH (CMSR)

“India- REACH” (or ICMS Rules or CMS Rules) which will replace existing Manufacture, Storage and Import of Hazardous Chemicals (MSIHC) Rules 1989 and Chemical Accidents (Emergency Planning, Preparedness and Response) (CAEPPR) Rules 1996. India REACH regulatory requirements shall come into force on the date of their publication in the Ofﬁcial Gazette, expected to come into force by the end of 2022.

All Chemical Substances must be Notiﬁed, and 750 “Priority substances” must be registered within 18 months.

All industrial sectors of the supply chain must comply with the CMSR, and non-Indian companies/enterprises must appoint an Authorized Representative (AR): an Indian entity, and AR, must comply with the CMSR on behalf of non-Indian companies.

Our Services
- Support for AR appointment process
- Service on registration/notiﬁcation, permits, performing duties on restrictions
- Providing latest news regarding REACH- Setting safety test strategies, arranging/monitoring tests

China REACH

It is a system in which a person (or manufacturer) who imports new chemical substances in China applies for registration of new chemical substances to China’s Ministry of Ecology Protection (MEE) prior to the date of import (or manufacture) and receives registration certiﬁcation. China’s MEE was amended on April 29, 2020 [Environmental Management System for New Chemical Substances] MEE Order. 12 was announced, and it came into effect on January 1, 2021.

Currently, there are 46,856 substances listed in China’s Inventory of Existing Chemical Substances (IECSC). Substances not listed on this list are considered as new chemicals.

Our Services
- Support for OR appointment process
- Submit to Chinese authorities
- Production of GLP test data required in China