ILMA Compoundings October 2016 - 40

INTERNATIONAL INSIGHT

For any who are unfamiliar, the Phase 1 registration under Taiwan
REACH is required for all importers of existing (inventory listed)
substances that are imported at annual volumes of one tonne
or higher. It is a one-time obligation for each importer per
existing (inventory listed) substance. It is not related in any way
to "new" substances not listed on the Taiwan inventory.

or above the one-tonne threshold. Once an importer files a
Phase 1 registration concerning an existing substance, it need
not be repeated going forward. Consequently, an importer
covered that was the subject of a Phase 1 registration for a
given substance filed last March need not ever file a Phase 1
registration for that substance again.

The Phase 1 Registration that was due this past March was a
benchmark filing for those who imported at or above threshold
volumes for the three prior years. As of the deadline (March 31,
2016), awareness and compliance (even by local importers) were
mixed.

The point here is that the same importer does need to file for
any other existing substances imported by them in 2016 or
beyond when they anticipate reaching the threshold volume for
that substance.

The story doesn't end there. From April 1, 2016, and forward
(indefinitely), it is incumbent on every Taiwan importer to
file a Phase 1 registration covering any chemical substance
imported/to be imported in a subsequent current year at

This topic matters to exporters to Taiwan for a couple of
reasons. Despite the obligation being on the importer, the
information required for filing is often proprietary to the
exporter. Also, the registration coverage in effect is supply chain
specific, and failure to file the registration results in market
ineligibility for that supply chain.
The compound risk to the exporter is that the absence of a
required Phase 1 registration concerning a specific supply chain
can close market access to the exporter, while the importer can
often shift to a competing supply chain. Hence, most exporters
choose to file the Phase 1 registrations on behalf of their
importers (both direct and indirect).

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If your importers are affected by the constituent substances
in your products, then you are an affected exporter. If your
importers are covered by a Phase 1 registration concerning your
exported volumes in 2015 and prior, you only need to watch
for other substances you export to them that were not already
covered last March.
If your importers are not yet covered for your substance
volumes, your immediate attention is strongly recommended.

Eggenschwiler is an international trade attorney and director
of global trade for the Redstone Group LLC. He can be
reached at 614-923-7472 or jeggenschwiler@redstonegrp.com.
Don't miss Eggenschwiler's presentation, New Developments in
the Global REACH Landscape: Asia-Pacific and Beyond, at the ILMA
Annual Meeting on Tuesday, October 18, 10:15 a.m. - 11:15 a.m.

Specialty Amines

1761 S. Naperville Road. Wheaton, IL 60189
Phone: 630.665.3085 | Toll Free: 800.665.3087
www.thhilson.com

Vol. 66 No. 10 * 40 * October 2016 Compoundings
http://www.thhilson.com
ILMA Compoundings October 2016

Table of Contents for the Digital Edition of ILMA Compoundings October 2016
