Taiwan to Tighten the Use of Organotin Compounds

By Xunyao Fu, PhD., senior regulatory specialist, Supply Chain team, UL Solutions 

Taiwan proposes to amend Categories and Management of Handling for Toxic Chemicals to tighten the prohibition and restriction of organotin compounds. The public comments end on Nov. 3, 2022. 

Taiwan publishes a draft amendment to Categories and Management of Handling for Toxic Chemical Substances which aims to tighten the use of organotin compounds. 

Taiwan’s Environmental Protection Administration (EPA) has published a draft amendment to the Categories and Management of Handling for Toxic Chemical Substances on Oct. 4, 2022. 

The regulation was first promulgated in 2007 and since then has gone through 13 sets of amendments. The main purpose of this revision is to strengthen the operational controls and management of organotin compounds. Organotin compounds are not easily decomposed and bio-concentrated, which can cause environmental pollution and human health risks. In accordance with the International Convention on the Control of Harmful Anti-fouling Systems on Ships on the management of organotin compounds, the use of organotin compounds in antifouling paints, antifouling systems and biocidal products will be prohibited in Taiwan. In addition, the toxicity of some organotin compounds is to be reclassified to strengthen the control on them.

The key points of the amendment are:

• Expand the scope of substances or articles not controlled by the regulation to medical devices, fertilizers, industrial use explosives, petroleum, natural gas, tobacco and alcohol which are administered by various regulations. (Article 5 and Article 14)
• Revise the toxicity classification of organotin compounds such as Tributyltin oxide and Triphenyltin hydroxide, and add the CAS registry number to Triphenyl-α-naphthyltin, Tripropyltin fluoride, Tritolyltin bromide and Tri(triphenylstannyl) methane. (Appendix Table 1)
• Amend the prohibited operations and permitted uses of the organotin compounds. (Appendix Table 2 and Appendix Table 3)
• Specify the deadlines for the completion of relevant matters in regard to the organotin compounds. (Appendix Table 4)

The draft amendments are currently open for public comments. To meet the expectations of the public as soon as possible, the period for public comments is shortened to 30 days (closing on Nov. 3, 2022) from the date the draft amendments were published. Any comments or concerns can be sent to EPA via their email address: yiting.chao@epa.gov.tw.

Recommended action items

• Check if your products contain any regulated organotin compounds.
• Submit any comments or concerns you might have to Taiwan's EPA.
• Keep an eye out for the publication of the official amendments.

References

Draft Amendments to Categories and Management of Handling for Toxic Chemical Substances (in traditional Chinese only)
Categories and Management of Handling for Toxic Chemical Substances (in traditional Chinese only)