India Chemical Management and Safety Rules (CMSR)

India has released the fifth draft of the Chemical (Management and Safety) Rules (CMSR). The regulation will replace two existing rules – Manufacture, Storage and Import of Hazardous Chemical Rules, 1989, and the Chemical Accidents (Emergency Planning, Preparedness and Response) Rules, 1996. It is similar to EU REACH regulation and also known as 'India REACH'. It is expected to be published in 2022.

The CMSR will apply to all substances, substances in mixture, substance in articles and intermediates that are manufactured, imported, or placed in the Indian Territory exceeding 1 TPA. It requires manufacturers, importers or Authorized Representatives to notify new and existing substances and register substances that need registration.

Enterprises's Obligations - Notification

Notification is required for all substances exceeding 1 TPA. The substance will be notified for certain uses and downstream users need to notify the Chemical Regulatory Division (CRD) if the intended use is not notified. Chemical Regulatory Division will issue a certificate of Notification along with Notification Number once the notified substance is evaluated for its completeness. All New Chemical Substances have to be notified at least 60 days prior to the date they are placed in Indian territory.

Data Requirements for Notification

• Detailed information of the Notifier
• Substance identification information
• Impurities
• Substance structural information and spectra
• Hazard classification
• Usage
• Downstream user
• Tonnage
• Maximum storage capacity
• SDS

Registration

Registration is required for identified substances that are listed in "Priority Substances Required to be Registered" in Schedule II of the CMSR and with the tonnage exceeding 1 TPA. Currently, there are 750 substances listed in Schedule II and the list will be updated. Registration should be carried out within 18 months after a substance is included in Schedule II.

Technical dossier is required for registration. For substance exceeding 10 TPA, a Chemical Safety Assessment is also required to be submitted along with Technical dossier. Registration fee will depend on tonnage band and company size.

The Intermediates listed in Schedule II with tonnage less than 1000 TPA should be registered with only the physical and chemical properties in the Technical Dossiers. Whereas Intermediates exceeding 1000 TPA should register with full information in the Technical Dossier along with the Chemical Safety Report (CSR). Priority Substances intended to be or likely to be released from the article under normal or foreseeable conditions of use with the tonnage exceeding 1 TPA will also need to register.

Annual Report

Annual report is required for both Notification and Registration. The report should contain the quantity of substance placed in India Territory in the previous calendar year and changes to the information submitted at the time of notification/registration. The annual report should be completed before the 29th Feb. / 1st Mar of each calendar year.

Our Services

• CMSR Compliance Analysis, Consulting and Training
• AR Authorisation
• Priority Substance Notification
• Priority Substance Registration
• Annual Report Preparation and Submission