Removing Regulatory Roadblocks
Expediting Market Access
> A Chinese company B is a subsidiary of a foreign company A with registered capital of about RMB 200 million, which does not meet the minimum registered capital requirements. However, considering the economic capacities and experience, company A thinks that its subsidiary B has the ability to bear the corresponding responsibilities and obligations of OR. Can company B serve as the OR of company A to complete China new chemical substance notification?
> A company has made scientific research record notification for a composition of an imported product. The company sells the product to company A for scientific research. However, company A makes the product prepared as automotive primer and sell it to company B who will finally use it on cars. Is it legal for company B to sell the cars coated with the automotive primer?
> Company A and B are both foreign companies. Company A has obtained the registration certificate of the new chemical substance P. Company A will sell substance P to company B, and B will re-sell it to company C. Does company C need to obtain the registration certificate?
> New chemical substance A has been notified by the domestic notifier. It is imported into China and then sold to another company for simple mixed processing without chemical reaction. Does the processed product need to be notified when exported to foreign countries?
> Factory A based in China manufactured a new chemical substance as raw material to be exported to Factory B outside the mainland of China for simple mixture and then be imported back to Factory A for labeling. In this case, does the Factory A need to apply for the registration certificate for the importation of the new chemical substance when it has obtained the registration certificate for manufacture activities?
> One Chinese domestic company X produces certain polymer and mixes it with other materials and solvents in the mixers of his factory so that a preparation is produced for barrel sales. Then in the application of a special case of simplified notification, can X consider himself as the processing/using party in the item 2.5 of the application form?
How to determine the hazard classification of mixtures?
If the new chemical substances has already been notified under SEPA Order 17 (predecessor of MEP Order 7), is it necessary to comply with the scientific research record notification under MEP Order 7?
What chemicals need to be registered?
Is registration needed if paint is imported, sub-packaged as commodities, and sold to downstream companies for direct selling in the market?
What hazardous chemicals need to go through legal inspection?
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