China's Taiwan Tightens Restrictions on Organotin Compounds

In Feb 2023, Taiwan's Environmental Protection Administration (EPA) and the Ministry of Agriculture published a Draft Amendment on the Toxic Chemical Substances Listed for Control and Relevant Operations and Management in which prohibits the use of organotin compounds including tributyltin oxide and triphenyltin chloride in the production of pesticides, anti-fouling paints or anti-fouling systems. Additionally, information on chemical substances will be updated and the management of chemical substances will be enhanced to prevent counterfeit pesticides and illegal use of chemicals. 

In the Draft Amendment, the Taiwanese EPA also proposed to adjust the regulations on the prohibition and restriction of organotin compounds based on the international control regulations and actual situations to prevent the misuse and abuse of organotin compounds. These ten organotin compounds, including tributyltin oxide and triphenyltin chloride, will be prohibited for manufacturing pesticides, anti-fouling paints or anti-fouling to strengthen the management of organotin compounds. Additionally, the Taiwanese EPA also proposed to update substance information based on international databases and relevant scientific researches. For example, CAS numbers of triphenyl-α-naphthyltin, tripropyltin fluoride, tritolyltin bromide and tritriphenylstannyl-methane will be added. The toxicity classification of organotin compounds including tributyltin oxide and triphenyltin hydroxide will be adjusted.

Conference has been held in Oct 2022 to discuss revisions to transportation, testing equipment, establishment of professional personnel and documentation updates. This conference also intends to amend provisions of comprehensive ban on asbestos in Taiwan.  

Main contents of this Amendment:

1. Exemptions of substances and articles is amended;
2. The toxicity classification of organotin compounds including tributyltin oxide and triphenyltin hydroxide is adjusted; CAS numbers of triphenyl-α-naphthyltin, tripropyltin fluoride, tritolyltin bromide and tritriphenylstannyl-methane are added;
3. Prohibited activities and intended uses of organotin compounds including tributyltin oxide are adjusted; and
4. Compulsory requirements of tributyltin oxide and triphenyltin hydroxide are added and stakeholders shall fulfill relevant obligations within the specified period.

Once approved, a grace period of 1 or 2 year will be provided for relevant enterprises and stakeholders may submit comments before November 3, 2023. 

Further Information:

Taiwanese EPA