Who is affected by China REACH?

Every manufacturer or importer who manufactures or imports a new chemical (pure, in a mixture, in a product with intended release or as a polymer) in China is required to file a notification with the CRC of MEP.

The notification for non Chinese companies can be done in two different ways:
- The Chinese Importer files the notification;
- A qualified Chinese company files the notification on behalf of the foreign company, similar to the EU REACH only representative

Both under There are several requirements which an only representative has to fulfill:
- The legal person has to be registered in the customs territory of the Chinese industry and trade ministry and has passed a yearly inspection;
- The legal person has a fixed office space;
- The registered minimum capital is a minimum of 3 million Chinese yuan (around 433,000 USD; October 2018);
- The employees have experience with the NCSN;
- The legal person has the qualifications to undertake the obligations and responsibilities under NCSN;
- The legal person agrees to surveillance and inspections through the MEP;
- The legal person did not violate China REACH in the last three years before the present notification;
- Chinese employees of the legal person are not members of the Ministry of Environmental Protection or the State Environmental Protection Administration.