As countries start to regulate chemicals, one of the first things they do is figure out what is already on the market and what is new. In most cases, they then introduce controls aimed at new substances – preferring to deal with the more complex question of existing chemicals separately.New Chemicals
There is no globally accepted definition of a “new” chemical but, at Asia in June, Karon Armstrong provided a round-up of the general criteria. Firstly, a substance must not be listed on an inventory or listed as a category on an inventory. It must not be a component of an article or an impurity, or a naturally occurring substance. Chemicals imported for R&D purposes do not qualify as new chemicals, nor do polymers that are eligible for exemption. Chemicals imported in low volumes or for export purposes only are also not considered new chemicals. If these criteria are fulfilled, a chemical must be registered as new.New Chemicals
However, companies are falling at the first hurdle. It is not always easy to determine if a chemical is new, simply by checking inventories. This is the case, for instance, if a substance has only recently been notified or notified as confidential. While the option to make confidential notifications is necessary to protect chemical identity, it is another hoop to jump through when determining if a chemical is new.New Chemicals
Timing is another factor. After notification approval of a substance, it is published in the Inventory Gazette. Sometimes, a notified chemical is immediately added to an inventory. This is most common if it has not been notified confidentially. Official listing takes place three to five years after approval. Until then, a new chemical cannot be manufactured or imported by a party other than the notifier, until a new manufacturer or importer submits a secondary notification. After a substance is notified, others may use the same substance without additional notification.
There are 12 main global inventories, belonging to Australia, Canada, China, the EU, Japan (two inventories), Korea, New Zealand, the Philippines, Switzerland (separate from the EU), Taiwan, Thailand and the US.