Janet Connochie our Senior Hazardous Substances Consultant, Compliance Certifier and Director has written this piece regarding the changes to the Hazardous Substances (Importers and Manufacturers) Notice 2015.
At present the Hazardous Substances (Importers and Manufacturers) Notice 2015 requires that importers and manufacturers of hazardous substances provide contact information to the EPA within 30 days of first importing or manufacturing (and update when contact details change as listed below).
- Name of the person (PCBU) importing or manufacturing
- Trading name (if different)
- Business address (or residential if no business address)
- Website address (if applicable)
- Details (name, email, phone number, designation/relationship to PCBU) of a contact person.
Information regarding substances is currently only required for Class 1 explosives that require a Controlled Substance Licence, and for fireworks (other than bonbon crackers, party poppers, and small pyrotechnic novelties).
We have seen the EPA undertake some enforcement action regarding non-compliance with supplying this information, and infringement notice offences around this were included in the consultation in mid-2023.
The EPA is currently consulting on four proposed changes to the Importers and Manufacturers notice as per below.
1. Additional information to be reported
- NZBN
- HSNO approval numbers (including Group Standard) for substances imported or manufactured
2. Annual quantity imported / manufactured for some substances with environmental effects
The EPA propose focusing on chemicals that generally have wide dispersive use and a high potential to enter the environment, particularly soil, freshwater, groundwater and the coastal marine area. Reporting is proposed for the quantities of active ingredients in the following groups of products.
- pesticides
- vertebrate toxic agents (VTAs)
- fumigants
- timber-treatment and antisapstain chemicals
- anti-fouling paints
- parasiticides used as veterinary medicines
- other chemicals of interest
3. Explosives regime to include manufacturers
The current requirements relate only to importers, and it is proposed to add manufacturers.
4. Option for multi-import certificates for explosives
At present import certificates are required per shipment, consultation is looking at a system for established importers to be granted multi-shipment import certificates.
The submissions close at 5pm on Thursday 28 March 2024, further information including discussion document and regulatory impact statement are available by clicking below.
Click below to see how Chemsafety can help you with your hazardous substance requirements.