Thailand Launches First National Existing Chemical Inventory

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July 21, 2020Chanyanis UtiskulBlog

On 8 July 2020 the Department of Industrial Works (DIW) under the Ministry of Industry (MOI) of Thailand issued the Notification of Department of Industrial Works Re: Inventory of Existing Chemicals in Thailand (No.1) B.E. 2563 (2020), dated 22 June 2020, announcing the first national chemical inventory of existing chemicals (DIW Chemical Inventory).

The DIW Chemical Inventory contains approximately 11,470 existing industrial chemicals that are manufactured, processed or imported in Thailand. They are required to comply with regulatory obligations under the Notification of Ministry of Industry Re: List of Hazardous Substances B.E. 2556 (2013), as amended through the 6th version of B.E. 2563 (2020) (List of Hazardous Substances).

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The DIW Chemical Inventory (1st version of 2020), operated on this site, replaces the database of the other inventory, i.e., DIW Preliminary Thailand Existing Chemicals Inventory, with updated data on chemicals collected up to 2017. The replaced inventory contained data from 2012-2015.

The inventory is a searchable database maintained by the Hazardous Substance Management Division under the DIW/MOI. It is deemed to be used as a tool for businesses and stakeholders. Users can either search chemicals by name, CAS RN, or other information and/or download the consolidated chemicals list from the online platform as a PDF or Excel file.

The current database (as of 10 July 2020) contains approximately 11,470 chemicals entries listed along with the following data:
•    Chemical name and CAS RN
•    Regulated type or class of chemicals as listed in the Annexes of the List of Hazardous Substances
•    Chemical group (general chemical, chemical of concern and chemical of high concern)
•    GHS Chemical Hazard Classification
•    Actual imported and production quantity

The DIW Inventory database contains a list of chemicals under the authority of the Ministry of Industry solely. They are considered hazardous substances, thus, have been listed in Annexes 5.1 to 5.5 of the List of Hazardous Substances. It also includes other chemicals that have been notified/declared to DIW/MOI and added to Annex 5.6 (List 5.6 Notification Framework).

Background on the Thailand Chemical Inventory

DIW/MOI developed the DIW Preliminary Thailand Existing Chemicals Inventory (Preliminary Inventory) in 2016 to support the above-mentioned List 5.6 notification framework. This framework places notification/declaration obligation on the importers and producers of chemicals that are not found in the current List of Hazardous Substances. It is part of Thailand’s ongoing move to the new chemical regulatory scheme.   

The inventory serves the purpose of providing information on the chemical substances circulating in the country and their related regulatory controls and obligations. Thailand has shown its intention to revamp its chemical regulatory scheme. The country implemented the National Chemical Management Plan No.4 (2012-2021) as a framework for better chemical management. The other draft legislation, i.e., the Draft Chemical Act (ร่างพระราชบัญญัติสารเคมีอันตราย), was put in place for public consultation in 2019, with an intention to replace the Hazardous Substances Act B.E. 2535 (1992) as amended through No.4 B.E. 2562 (2019). This Draft Law mandates the establishment of the National Chemical Inventory. In addition, upon implementation chemicals introduced into Thailand will be subject to risk assessment, classification, assignment and control based on the three designated lists of chemicals. This indicates that it is Thailand’s intention to progress toward the new chemical control scheme, but many expect that there is a long way to go.

In addition to the DIW Chemical Inventory, Thailand has another inventory in place, the Thailand Existing Chemicals Inventory (TECI) which is operated by the Chemical Safety Group under the Food and Drug Administration under the Ministry of Health.

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Chemical importers and manufacturers should use the DIW Chemical Inventory for reference/advisory purposes. According to the DIW authorities, the main purpose of the inventory at this time remains unchanged, i.e., to be an assistive tool to the industry/stakeholders. It also serves as a basic tool for Thailand in adopting a new chemical regulatory approach. The publication of the inventory does not create any additional regulatory obligations other than those required by the Hazardous Substance Act and the List of Hazardous Substances or other applicable laws.

The inventory contains only chemicals that are under the sole responsibility of the Ministry of Industry. Businesses wishing to introduce chemical substances to Thailand must still check whether their product is listed under the List of Hazardous Substances to determine regulatory obligations. Similar chemicals can be found on more than one list. This means they are subject to different types of regulatory control conditions.