On September 18, 2026, the Environmental Protection Administration (EPA) of Taiwan, China published a pre-announcement proposing to amend the basis clauses of two announcements, "Restriction on the Import of Mercury-Containing Products" and "Restriction on the Import of Cleaners Containing Nonylphenol and Nonylphenol Ethoxylates." Both amendments are merely a transfer of the legal basis made to align with changes to superior statutes; the regulated products and the control requirements under the announcements remain unchanged. The deadline for submitting comments is October 2, 2026.
Background of the Amendment: Alignment with Revisions to the Waste Disposal Act and the Resource Circulation Promotion Act
The two announcements were originally issued under Article 21 of the Waste Disposal Act. As the Waste Disposal Act and the Resource Circulation Promotion Act were revised and promulgated on July 15, 2026, and June 17, 2026, respectively, the authorizing basis of the relevant announcements must be adjusted accordingly.
After the amendment, the basis of the "Restriction on the Import of Mercury-Containing Products" announcement will be changed to paragraph 2 of Article 18 of the Resource Circulation Promotion Act, and the basis clauses of the "Restriction on the Import of Cleaners Containing Nonylphenol and Nonylphenol Ethoxylates" announcement will be revised in parallel. Both announcements add the wording "and shall take effect from the date of promulgation," meaning they enter into force immediately upon the amendment's publication.
Current Status of the Two Announcements and the Changes This Time
The "Restriction on the Import of Mercury-Containing Products" announcement was promulgated on August 25, 2020, and was last amended on June 22, 2026, taking effect on July 1, 2026. This amendment concerns only the basis clauses and the manner of entry into force; the product restriction list is not adjusted.
The "Restriction on the Import of Cleaners Containing Nonylphenol and Nonylphenol Ethoxylates" announcement was promulgated on June 4, 2025, and took effect on the same day. Under the original announcement, the import restriction on nonylphenol cleaners is phased in (concentrations above 5% from December 1, 2026, and above 0.1% from June 1, 2027). It has not been amended to date. This time, likewise, only the basis clauses are modified.
Pre-announcement Period Shortened to 14 Days
In the pre-announcement, the EPA explained that both announcements involve only a basis adjustment made to align with statutory revisions and have no material impact on the rights and interests of the public. Therefore, pursuant to Article 151, paragraph 2, applied mutatis mutandis to Article 154, paragraph 1 of the Administrative Procedure Act, the pre-announcement period is shortened to 14 days, below the standard 60-day period.
Impact on Relevant Enterprises
This pre-announcement does not change the current control requirements for the products covered by the two announcements. Exporters of mercury-containing products and of cleaners containing nonylphenol and nonylphenol ethoxylates need not adjust their compliance arrangements on account of this amendment.
Comments may be submitted by October 2, 2026, to the Resource Circulation Administration of the EPA via email (chcliu@moenv.gov.tw).
