The China REACH Standard T/ZTCA 011.1-2022

On October 31^st, 2022, China REACH standard T/ZTCA 011.1—2022, also known as the Automotive Industry Control of Key Chemical Substances, came into effect. The standard is a voluntary resource for manufacturers in China’s automotive industry to help them comply with the European Union’s EU REACH regulation.

Let’s start by looking at the European basis for the China REACH standard.

EU REACH

EU REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) is a multifaceted regulation.

The titular registration and evaluation steps apply to manufacturers wishing to put new chemicals onto the EU market. Indeed, if the substance is unknown to the ECHA (European Chemicals Agency), the manufacturers must submit an inquiry. They will work with other companies claiming the same compound to prepare a registration dossier. With this system, it is the manufacturer’s responsibility to certify the identity and possible dangers of the new substance.

Next, an authorization process exists for the Substances of Very High Concern (SVHC) under annex XIV of EU REACH. The list is updated every six months. Manufacturers must declare when their articles use these chemicals above a threshold of 0.1% w/w before they are allowed in the EU.

Finally, the restriction of chemicals refers to prohibited substances entered in Annex XVII. The list also offers specific conditions for banning the compounds. One example of a forbidden substance is nickel when it comes into direct contact with the user’s skin, such as switches or buttons.

Now we can look closer at China’s regulations.

What is the China REACH Standard?

The Zhongguancun Inspection, Testing and Certification Industrial Technology Alliance partnered with various organizations across the automotive industry to develop standard T/ZTCA 011.1—2022. It includes a list of chemicals that mirrors EU REACH’s SVHCs. Its similarities to the European regulation lend it to be called China REACH. The standard focuses on substances likely to be important in the automotive industry and provides analytical testing guidelines.

Why Was China REACH Standard T/ZTCA 011.1-2022 Developed?

Unlike EU REACH, China REACH is not a law. It serves as a reference to prepare manufacturers within the automotive industry to export their products to the European Union. Hence, it is easier to develop preventative measures to avoid the costly consequences of violating EU REACH. Each member state of the EU has unique enforcement policies ranging from product recalls to criminal penalties. The standard compensates for the lack of Chinese law closely resembling EU REACH that forces manufacturers to limit their use of SVHCs.

On the other hand, other Chinese legislation equally exists for the automotive industry. One example is standard GB/T 30512-2014, otherwise known as Requirements for Prohibited Substances on Automobiles. It covers testing methods for the following six chemicals.

Lead
Cadmium
Mercury
Hexavalent chromium
Polybrominated biphenyls
Polybrominated diphenyl ethers

In this case, the EU RoHS and China RoHS (Restriction of Hazardous substances) also place prohibitions on the above substances but only in electronic and electrical products. Standard GB/T 30512-2014 allows the automotive industry to test for the same compounds in their materials. However, the limited number of chemicals does not help manufacturers achieve EU REACH compliance.

Are There More China REACHs?

You may have heard China REACH refer to the Chinese Ministry of Ecology and Environment‘s (MEE) Order No. 12, also called the New Chemical Substance Registration. Unlike standards, Orders are compulsory regulations in China. This law stipulates that any chemicals missing from the IECSC (Inventory of Existing Chemical Substances in China) must be registered with the MEE before they can be sold or imported into China. Thus, the comparison lies in the chemical registration aspect of EU REACH.

For more information on REACH Regulations, contact Enviropass.