By Fang Lin on Sunday, 13 April 2014 in Agrochemical News 

On April 3 2014, China Ministry of Environmental Protection released the final version of the “Catalogue of Hazardous Chemical of Priority Environmental Concern” (HCPEC List). A total of 9 pesticide active ingredients are included in the final list, compared with the previous draft list which contained 12 active ingredients and 3 formulated products. 

The list was drafted under the “MEP Order 22-Measures for the Environmental Management of Hazardous Chemical Registration (trial)”. Manufacturers and user of HCPECs are required to obtain registration certification for environmental management of hazardous chemical registration and submit the environmental risk assessment report and annual PR&TR report to the competent authority of environmental protection.

During March and April 2013, MEP circulated the first HCPEC draft to the industry for feedback. The vast majority of pesticide manufacturers and users have reacted with indifference to the issuance of the draft. Most Chinese pesticide producers believe that having already completed  pesticide  registration and submitted comprehensive dossiers, which have already been assessed and approved by the MoA that the MEP measures are of little relevance. However according to MEP order 22 companies are also required to file application materials to county-level authority of environmental protection.

Before the release of the HCPEC list, MEP summoned several key representatives from the pesticide industry to get important feedback on issues relating to the HCPEC list. Industry is already utilizing technical materials contained in the list to produce formulated products. The coexistence of pesticide active ingredients and formulated products in the HCPEC draft has caused great confusion as to whether or not downstream formulating companies are obligated to obtain environmental management registration. MEP has yet to provide a definitive explanation on this issue. However we can presume from looking at the final list which has contains no pesticide formulated products that the formulating companies will be obligated to fulfill HCPEC regulatory requirements.

The silver lining for industry is that three active ingredients included in the draft list have been removed from the final version. They are the trichlorfon, phoxim and the triallate. Currently, these three pesticides account for 113, 990 and 5 pesticide registration certificates respectively. The removal of trichlorfon and phoxim was primarily due to their shrinking market and minimal domestic market share. Though there are only 5 ICAMA registrants of triallate, the herbicide is expected to meet increased demand in the future and China does not want to prematurely disadvantage its domestic producers.