Thailand
Following a presentation by the Department of Industrial Works (DIW) given in Q3 2015 it appears that Thailand will develop a national chemical inventory similar to other countries.
The following represents the current understanding:
• Closure of existing chemical nomination is initially proposed for December 31, 2016. The Government has asked industry if this provisional lead time is acceptable. The due date will be finalized later. After the closure of nomination, chemicals not listed on the existing chemical inventory will be considered to be new, and a notification will be required.
• The current registration and license is required when produce / import any amount of a regulated substance, for mixtures the scope is for regulated substances at >1%. The notification process for non-regulated chemicals is required when >1000 kgs/year, in case that lower than 1000 kgs, it is voluntary to nominate in order to add the chemical to Existing List in government system.
• DIW will endeavor to combine its hazardous substance list, the latest hazardous chemical notification list, the chemicals listed in the DIW consultation database and possibly the National Single Window List from the Customs. DIW will then define these chemicals as “existing”.
A great deal of uncertainty exists; hence strenuous efforts will be made to obtain further clarity.
Potential Impacts on Syngenta:
• Import & sourcing: Since we have a formulation site in Thailand and we import various chemical raw materials in to Thailand, we will be affected by the planned new substance notification regulation. To avoid expensive REACH-like notification in Thailand, we shall closely monitor the situation. Once the existing substance nomination starts, it is very important that we nominate all substances in our CP products and all chemical substances we buy from Thailand onto the inventory.
Thailand
Following a presentation by the Department of Industrial Works (DIW) given in Q3 2015 it appears that Thailand will develop a national chemical inventory similar to other countries.
The following represents the current understanding:
• Closure of existing chemical nomination is initially proposed for December 31, 2016. The Government has asked industry if this provisional lead time is acceptable. The due date will be finalized later. After the closure of nomination, chemicals not listed on the existing chemical inventory will be considered to be new, and a notification will be required.
• The current registration and license is required when produce / import any amount of a regulated substance, for mixtures the scope is for regulated substances at >1%. The notification process for non-regulated chemicals is required when >1000 kgs/year, in case that lower than 1000 kgs, it is voluntary to nominate in order to add the chemical to Existing List in government system.
• DIW will endeavor to combine its hazardous substance list, the latest hazardous chemical notification list, the chemicals listed in the DIW consultation database and possibly the National Single Window List from the Customs. DIW will then define these chemicals as “existing”.
A great deal of uncertainty exists; hence strenuous efforts will be made to obtain further clarity.
Potential Impacts on Syngenta:
• Import & sourcing: Since we have a formulation site in Thailand and we import various chemical raw materials in to Thailand, we will be affected by the planned new substance notification regulation. To avoid expensive REACH-like notification in Thailand, we shall closely monitor the situation. Once the existing substance nomination starts, it is very important that we nominate all substances in our CP products and all chemical substances we buy from Thailand onto the inventory.
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