TAIWAN CHEMICAL REGULATORY UPDATE
The Chemicals Administration under the Ministry of Environment in Taiwan held a stakeholder consultation meeting on 22 October 2026 to discuss proposed controls on six additional substances as Concerned Chemical Substances: Toluidine Red, Para Red, bisphenol B, bisphenol F, MMMP and gamma-butyrolactone (GBL).
The proposed amendments would set substance-specific control concentrations and requirements for manufacture, import, sale, use and storage. The six substances were not formally listed as a result of the consultation meeting. The amendments remain at the draft stage, and the final requirements and implementation dates are subject to an official announcement. The official meeting page provides the draft amendments and presentation.
For overseas suppliers, importers and downstream users, the immediate task is to establish whether their products contain these substances at the proposed thresholds. GBL requires particular attention: reaching the proposed 20% threshold would not automatically trigger the same obligations as supplying or handling GBL at 90% or above.
Quick Navigation
Which Substances and Supply Chains Could Be Affected?
The draft was initially announced on 20 July 2026. The October meeting forms part of the subsequent consultation process.
| Substance | CAS number | Proposed control concentration | Potentially relevant applications and sectors |
|---|---|---|---|
| Toluidine Red | 2425-85-6 | ≥30% | Pigments, printing inks, coatings and plastics coloration |
| Para Red | 6410-10-2 | ≥30% | Pigments and coloring materials |
| Bisphenol B (BPB) | 77-40-7 | ≥1% | Resins, plastics and related raw materials |
| Bisphenol F (BPF) | 620-92-8 | ≥1% | Epoxy resins, coatings and adhesives |
| MMMP (Photoinitiator 907) | 71868-10-5 | ≥90% | UV-curable inks, coatings and adhesives |
| Gamma-butyrolactone (GBL) | 96-48-0 | ≥20%, with additional requirements at ≥90% | Industrial solvents, electronic chemicals and fine chemicals |
The applications above are illustrative examples based on common industrial uses, not an official list of affected sectors. Applicability depends on the substance identity, actual concentration and handling activity.
The proposal addresses three main concerns:
Food and feed safety: Toluidine Red and Para Red would be listed in the category covering chemicals associated with food safety concerns, to help prevent industrial chemicals from entering food and feed supply chains.
Potential endocrine effects: BPB and BPF would be added to the category addressing public and consumer concerns.
Misuse risks: MMMP and GBL would be subject to additional controls over handling and distribution.
Businesses should assess these proposed controls alongside their wider chemical compliance responsibilities. REACH24H's Taiwan TCCSCA and OSHA Chemical Registration Services explain the separate registration framework for new and existing chemical substances.
What Handling Requirements Are Proposed?
For substances and activities subject to the full set of proposed controls, the main requirements would include:
Approval documents: Obtain the required approval for regulated handling activities, subject to the applicable transitional arrangements.
Records and reporting: Maintain records of each regulated handling activity and submit monthly reports.
Labeling and safety information: Meet applicable labeling requirements and maintain safety data sheets (SDS).
Additional warnings: Mark containers and packaging for Toluidine Red and Para Red with the Chinese warning meaning "Prohibited for use in food and feed." MMMP and GBL would carry the Chinese warning meaning "For industrial use only."
These proposed requirements concern the handling of substances that may be designated as Concerned Chemical Substances. They should be assessed separately from new or existing chemical substance registration.
GBL: Different Obligations at 20% and 90%
The draft provides a tiered approach for GBL:
| GBL concentration | Proposed treatment |
|---|---|
| ≥20% but <90% | Containers and packaging would be subject to the applicable requirements under the labeling and SDS management regulations. Other handling activities would not be restricted under the Act through this proposed listing. |
| ≥90% | The applicable handling controls would extend to approval documents, transaction records, monthly reporting, labeling and SDS requirements. |
A product containing 25% GBL should therefore not automatically be assigned the same compliance obligations as a product containing 95% GBL. Suppliers and local operators should confirm the actual concentration and assess the applicable tier before planning approval applications or reporting arrangements.
The reduced requirements for the lower concentration band should not be interpreted as an exemption from every other chemical, workplace or product-related obligation.
Proposed Transition Dates Remain Subject to Change
For businesses already handling the substances, the draft proposes the following timetable, where the relevant obligation applies:
| Management requirement | Proposed timing |
|---|---|
| Start keeping handling records and submit periodic reports | From 1 January 2027 |
| Complete labeling of containers, packaging, handling premises and facilities, and maintain SDS | Before 1 July 2028 |
| Obtain required approval documents | Before 1 July 2028 |
| Comply with other matters not listed in the transition table | From the date of the official announcement |
These are draft dates, not confirmed compliance deadlines. The meeting presentation states that the timetable will be adjusted according to the actual announcement date. Companies should also note that recordkeeping is proposed to start earlier than the deadlines for labeling and approval documents.
In response to concerns about the burden on smaller businesses, the Chemicals Administration described an approximately 18-month adjustment period for container labeling and obtaining approval documents. It also outlined plans for briefings, online information, consultation channels and guidance after the amendments formally take effect.
The meeting presentation invited participating organizations to submit further written comments by 29 October 2026. The authority will consider the feedback as it proceeds with the amendments.
What Should Suppliers and Local Operators Do Now?
REACH24H recommends using the draft stage to prepare a product-specific assessment:
Screen by CAS number and concentration. Check raw materials and formulations against all six entries. A trade name alone may not establish whether a product falls within scope.
Map the activities performed in the Taiwan region. Identify who manufactures, imports, sells, uses or stores each potentially affected material.
Separate the GBL concentration bands. Confirm whether products fall below 20%, between 20% and less than 90%, or at 90% and above.
Review information readiness. Identify gaps in composition data, SDS, proposed warning labels and transaction records. Overseas suppliers should coordinate the necessary product information with their local importers and customers.
Track the final announcement. Recheck substance coverage, concentration thresholds, management requirements and transition dates before treating the draft as an implementation schedule.
The value of early preparation is a clear view of affected products and responsible operators, supported by reliable substance information.
REACH24H Support for Taiwan Chemical Compliance
REACH24H supports overseas manufacturers, local importers and regulatory teams with TCSI inventory searches and registration applicability assessments, new and existing substance registration, data gap analysis and dossier preparation, and post-registration maintenance.
For businesses reviewing the six proposed substances, these broader registration needs should be considered alongside the specific handling controls discussed above. Our Taiwan chemical registration services provide further information on the available support.
Planning chemical supply to the Taiwan market?
Share your substance names, CAS numbers, composition, intended uses and supply arrangements with REACH24H to discuss your compliance needs.
